Friday, November 15, 2013

General Dynamics Land Systems, Inc. v. Cline case brief

General Dynamics Land Systems, Inc. v. Cline case brief summary
540 U.S. 581 (2004)

Respondents, employees and retirees, sued petitioner employer, asserting a reverse age discrimination claim under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C.S. § 621 et seq., based upon a collective-bargaining agreement. The district court dismissed the claim. The United States Court of Appeals for the Sixth Circuit reversed the district court's dismissal. Certiorari was granted.

Respondents, who were between 40 and 50 years old, objected to the new terms of a collective-bargaining agreement, which eliminated the employer's obligation to provide health benefits to subsequently retired employees, except as to then-current workers at least 50 years old. Respondents alleged that the agreement violated the ADEA because it discriminated against them with respect to compensation, terms, conditions, or privileges of employment, because of their age.

Based upon the ADEA's text, structure, purpose, and history, the Supreme Court determined that the ADEA did not prohibit favoring the old over the young. The ADEA was concerned with protecting a relatively old worker from discrimination that worked to the advantage of the relatively young. "Age" meant one thing in29 U.S.C.S. § 623(a)(1) and another in § 623(f). The Court did not decide the deference issue regarding 29 C.F.R. § 1625.2(a) (2003), because the Equal Employment Opportunity Commission was clearly wrong in its interpretation of the ADEA.


The Court reversed the appellate court's judgment.

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