Reeves v. Sanderson Plumbing Products, Inc.

PETITIONER: Reeves
RESPONDENT: Sanderson Plumbing Products, Inc.
LOCATION: Massachusetts Office for Administration and Finance

DOCKET NO.: 99-536
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 530 US 133 (2000)
ARGUED: Mar 21, 2000
DECIDED: Jun 12, 2000

ADVOCATES:
Jim Waide - Argued the cause for the petitioner
Patricia A. Millett - Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the petitioner
Taylor B. Smith - Argued the cause for the respondent

Facts of the case

Roger Reeves, 57, and Joe Oswalt, in his mid-thirties, were supervisors in different Sanderson Plumbing Products, Inc. departments. Reeves' duties included making sure workers under his supervision were on time and at work and logging such data. Reeves' department was managed by Russell Caldwell, 45, who was responsible for reviewing Reeves' work. Caldwell informed the company's director of manufacturing, Powe Chesnut, that production in Revees' department was down because employees were often absent, coming in late, and leaving early. Chesnut ordered an audit, which revealed numerous timekeeping errors and misrepresentations by Caldwell, Reeves, and Oswalt. Chesnut recommended that Reeves and Caldwell be fired and, subsequently, their employment was terminated. Reeves filed suit, alleging that he had been terminated because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA). At trial, Sanderson contended that Reeves was fired because of his failure to maintain accurate attendance records. Reeves attempted to demonstrate that this explanation was a pretext for age discrimination and introduced evidence that he had accurately recorded the attendance of employees under his supervision and that Chesnut had demonstrated age-related animosity when dealing with him. Ultimately, the case went to a jury, which returned a verdict for Reeves. In reversing, the Court of Appeals concluded that Reeves had not presented sufficient evidence to sustain a finding of age-based discrimination.

Question

Is a plaintiff's prima facie case of age discrimination, combined with sufficient evidence for a reasonable factfinder to reject the employer's nondiscriminatory explanation for its decision, adequate to sustain a finding of liability for intentional discrimination under the Age Discrimination in Employment Act of 1967?

Media for Reeves v. Sanderson Plumbing Products, Inc.

Audio Transcription for Oral Argument - March 21, 2000 in Reeves v. Sanderson Plumbing Products, Inc.

Audio Transcription for Opinion Announcement - June 12, 2000 in Reeves v. Sanderson Plumbing Products, Inc.

William H. Rehnquist:

The opinion of the Court in No. 99-536 Reeves versus Sanderson Plumbing Products Inc. will be announced by Justice O’Connor.

Sandra Day O'Connor:

This case comes to us on writ of certiorari to the Court of Appeals for the Fifth Circuit.

In October 1995, the petitioner Roger Reeves, a man of age 57, was fired by the respondent Sanderson Plumbing from his position as a supervisor.

Reeves filed suit claiming he had been discharged because of his age in violation of the Age Discrimination in Employment Act.

Respondent Sanderson Plumbing in turn asserted that it had terminated petitioner because he had inaccurately recorded the attendance of the employees under his supervision.

The case was tried before jury, the jury found the respondent employer liable for age discrimination.

But the Court of Appeals reversed, holding that respondent was entitled a judgment as a matter of law.

In an opinion filed with the Clerk of the Court today, we reverse the judgment of the Court of Appeals.

In awarding respondent judgment as a matter of law, the Court of Appeals preceded from the premise that a plaintiff’s prima facie case of discrimination, combined with proof that the employer’s non-discriminatory explanation is false, is always insufficient without more to sustain a verdict of discrimination.

But our decision in an earlier case, St. Mary's Honor Center versus Hicks makes clear that such a showing by the plaintiff may permit a reasonable factfinder to infer that the employer unlawfully discriminated.

Proof that the employer’s proffered explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination and depending on the circumstances it may be quite persuasive.

The Court of Appeals therefore erred in assuming that a plaintiff must always produce additional independent evidence of discrimination.

In this case, judgment as a matter of law after the jury verdict was inappropriate.

In deciding the motion for judgment as a matter of law under Rule 50 of the Federal Rules of Civil Procedure the court should review all of the evidence in the record, but it must draw all reasonable inferences in favor of the moving party, and it may not make credibility determinations or weigh the evidence.

Thus, it should only give credence to the evidence favoring the non-moving party as well as that evidence supporting the moving party that the jury is required to believe.

Applying that standard here, we find the District Court was correct to submit the case to the jury.

The Court of Appeals impermissibly substituted its judgment concerning the weight of evidence for the juries.

The opinion of the Court is unanimous.

Justice Ginsburg has filed a concurring opinion.