Hazen Paper Company v. Biggins

PETITIONER: Hazen Paper Co., Robert Hazen, Thomas N. Hazen
RESPONDENT: Walter F. Biggins
LOCATION: Hazen Paper Company

DOCKET NO.: 91-1600
DECIDED BY: Rehnquist Court (1991-1993)
LOWER COURT: United States Court of Appeals for the First Circuit

CITATION: 507 US 604 (1993)
ARGUED: Jan 13, 1993
DECIDED: Apr 20, 1993
GRANTED: Jun 22, 1992

ADVOCATES:
John R. Dunne - on behalf of the United States as amicus curiae supporting the Respondent
Maurice M. Cahillane, Jr. - on behalf of the Respondent
Robert B. Gordon - on behalf of the Petitioner

Facts of the case

Hazen Paper Company fired Walter F. Biggins, a 62-year-old employee who worked for Hazen for just under 10 years. Biggins’ pension was set to vest at the completion of 10 years of service. Biggins sued Hazen and its owners, alleging that his termination violated the Age Discrimination in Employment Act (ADEA) and several provisions of the Employment Retirement Income Security Act (ERISA). At trial, the jury ruled in favor of Biggins, finding that Hazen violated ERISA and “willfully” violated the ADEA. The willful violation gave rise to liquidated damages. The district court judge granted Hazen’s motion for judgment notwithstanding the verdict, reversing the finding of willfulness which eliminated the liquidated damages. The U.S. Court of Appeals for the First Circuit affirmed the jury verdict and reversed the finding of willfulness, holding that Hazen knowingly violated the ADEA by showing a “reckless disregard” for the matter.

Question

Did the Courts below err in sustaining Biggin's claim under the ADEA, where the finding of age discrimination was based on pension vesting?

Did the Court of Appeals err in reinstating an award of liquidated damages for willful ADEA violation that had been set aside by the District Court?

Media for Hazen Paper Company v. Biggins

Audio Transcription for Oral Argument - January 13, 1993 in Hazen Paper Company v. Biggins

Audio Transcription for Opinion Announcement - April 20, 1993 in Hazen Paper Company v. Biggins

Sandra Day O'Connor:

The second case is Hazen Paper Company against Biggins which comes to this Court on writ of certiorari to the United States Court of Appeals for the First Circuit.

The respondent was employed by petitioner Hazen Paper Company.

He was fired when he was 62 years old.

He brought suit against the petitioners and Federal District Court claiming that he had received discriminatory treatment under the Age Discrimination and Employment Act of 1967.

The jury found in respondent's favor and also found that the petitioners had committed a willful violation of the statute.

Under the Age Discrimination and Employment Act, a willful violation gives rise to liquidated damages.

Petitioners move for judgment not withstanding the verdict.

The District Court granted the motion with respect to the finding of willfulness.

The Court of Appeals upheld the verdict of liability, giving emphasis to the evidence that petitioners had fired the respondent in order to prevent his pension benefits from vesting.

On the issue of willfulness, the Court of Appeals applied the standard set out in Trans World Airlines against Thurston and reversed the judgment not withstanding the verdict.

We hold in the opinion filed today, that an employer does not commit discriminatory treatment under the Age Discrimination and Employment Act by firing an employee whose pension benefits are about to vest, where vesting is linked to the employee's years of service.

The Act generally prohibits employment decisions based on the employee's age, not decisions based on factors that are analytically distinct from age, such as years of service.

Congress passed the Age Discrimination and Employment Act because employers were relying on inaccurate and stigmatizing stereotypes about age.

Pension interference violates the Act known as ERISA, the Employees Income and Retirement Act, but it does not amount to discriminatory treatment under the Age Discrimination and Employment Act.

On the issue of willfulness, we hold that the Thurston definition is generally applicable to discriminatory treatment cases under that Act.

Thurston held that a violation of the Act would be willful if the employer knew or showed reckless disregard for the matter of whether its conduct was prohibited by the Act.

We see no relevant difference between an employer who has a formal policy that discriminates on the basis of age, which was the case in Thurston, and an employer who makes an informal decision that is motivated by the employee's age.

The judgment of the Court of Appeals is vacated and the case is remanded.

Justice Kennedy has filed a concurring opinion in which the Chief Justice and Justice Thomas have joined.