Reeves v. Sanderson Plumbing Prods. Inc.

Brief Fact Summary.

Plaintiff sued Defendant under the ADEA, alleging that his discharge waws impermissibly based on his age. The jury found in favor of Plaintiff. The court of appeals reversed. Plaintiff appealed.

Synopsis of Rule of Law.

A plaintiff’s prima facie case of discrimination, combined with sufficient evidence for a reasonable fact finder to reject the employer’s nondiscriminatory reason for its decision, is adequate to sustain a finding of liability for intentional discrimination.

Facts.

Roger Reeves (Plaintiff), 57, sued his former employer, Sanderson Plumbing Products Inc. (Defendant) under the Age Discrimination in Employment Act (ADEA), alleging that his discharge from Defendant was impermissibly based on his age. Defendant claimed that Plaintiff was terminated because he was responsible for numerous timekeeping errors and misrepresentations relating to the department he oversaw, the Hinge Room. At trial, Plaintiff presented evidence that Defendant’s proffered reason for his termination was pretextual. For example, there was testimony that Plaintiff’ supervisor, Powe Chestnut, said that Plaintiff was “so old he must have come over on the Mayflower,” and that Chestnut treated Plaintiff the way one would treat a child who had misbehaved. During the trial, Defendant made two motions for judgment and a matter of law under Rule 50, both of which were denied. The jury found in favor of Plaintiff, and Defendant made a third motion for a judgment as a matter of law, which was denied. The court of appeals reversed, holding that Plaintiff had not presented enough evidence to sustain the jury’s verdict of intentional discrimination. The court of appeals found that although Plaintiff may have shown that Defendant’s reason for his termination was pretextual, he had failed to show the connection between his termination and Defendant’s discrimination. Plaintiff appealed, and the United States Supreme Court granted certiorari.