''Meacham v. Knolls Atomic Power Laboratory'', 554 U.S. 84 (2008), was a case decided by the

Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all Federal tribunals in the United States, U.S. federal court cases, and over Stat ...

on June 19, 2008. The Court decided that an employer bears both the burden of production and burden of persuasion when defending a

disparate impact Disparate impact in the law of the United States refers to practices in employment, housing, and other areas that adversely affect one group of people of a protected characteristic more than another, even though rules applied by employers or landl ...

claim using the "reasonable factors" defense under the

Age Discrimination in Employment Act of 1967 The Age Discrimination in Employment Act of 1967 (ADEA; to ) is a United States labor law that forbids employment discrimination against anyone, at least 40 years of age, in the United States (see ). In 1967, the bill was signed into law by Pr ...

(ADEA).''Meacham v. Knolls Atomic Power Laboratory'',

554 __NOTOC__ Year 554 ( DLIV) was a common year starting on Thursday of the Julian calendar. The denomination 554 for this year has been used since the early medieval period, when the Anno Domini calendar era became the prevalent method in Europe ...

U.S. The United States of America (USA), also known as the United States (U.S.) or America, is a country primarily located in North America. It is a federal republic of 50 states and a federal capital district, Washington, D.C. The 48 contiguous ...

84 (2008){{Cite web , title=Meacham v. Knolls Atomic Power Laboratory, 554 U.S. 84 (2008) , url=https://supreme.justia.com/cases/federal/us/554/84/ , access-date=2023-08-29 , website=Justia Law , language=en

Background

When

Knolls Atomic Power Laboratory Knolls Atomic Power Laboratory (KAPL) is an American research and development facility based in Niskayuna, New York and dedicated to the support of the U.S. Naval Nuclear Propulsion Program. KAPL was instituted in 1946 under a contract between ...

(KAPL) conducted a reduction in force in 1996, the employees were assessed based on factors of performance, flexibility, criticality of skills, and years of service. 31 employees were eventually laid off and 30 of them were at least 40 years of age. 26 of these employees filed suit against KAPL asserting, ''inter alia,'' disparate impact based on age under the ADEA. At trial, a jury found for the employees on the disparate impact claim and the

United States Court of Appeals for the Second Circuit The United States Court of Appeals for the Second Circuit (in case citations, 2d Cir.) is one of the thirteen United States Courts of Appeals. Its territory covers the states of Connecticut, New York (state), New York, and Vermont, and it has ap ...

initially affirmed. On appeal, the U.S. Supreme Court vacated the judgment and remanded the case due to its 2005 ''

Smith v. City of Jackson ''Smith v. City of Jackson'', 544 U.S. 228 (2005), was a case decided by the Supreme Court of the United States on March 30, 2005. It concerned the Age Discrimination in Employment Act of 1967 (ADEA) and the disparate impact theory. The Court hel ...

'' decision. The Second Circuit then vacated its previous decision and held that the petitioners failed to carry their burden of persuasion to prove that KAPL's method of evaluating employees was unreasonable. The employees then appealed to the U.S. Supreme Court."Meacham v. Knolls Atomic Power Laboratory." ''Oyez,''www.oyez.org/cases/2007/06-1505. Accessed 29 Aug. 2023.

Result

In a 7–1 decision vacating the Second Circuit's judgment, the Court held that when defending a disparate impact claim using the "reasonable factors other than age" defense under the ADEA, the employer is the one that bears both the burden of production and burden of persuasion.

References

United States Supreme Court cases United States Supreme Court cases in 2008 Anti-discrimination case law in the United States

Background

Result

See also

References