''Smith v. City of Jackson'',

544 __NOTOC__ Year 544 ( DXLIV) was a leap year starting on Friday of the Julian calendar. The denomination 544 for this year has been used since the early medieval period, when the Anno Domini calendar era became the prevalent method in Europe fo ...

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 ...

228 (2005), 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 March 30, 2005. It concerned 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) and the

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 ...

theory. The Court held that although the theory of disparate impact set forth in '' Griggs v. Duke Power Co.'',

401 __NOTOC__ Year 401 ( CDI) was a common year starting on Tuesday of the Julian calendar. At the time, it was known as the Year of the Consulship of Vincentius and Fravitus (or, less frequently, year 1154 ''Ab urbe condita''). The denomination ...

424 (1971) is also applicable under the ADEA, the ADEA is narrower as it permits “otherwise prohibited” actions “where the differentiation is based on reasonable factors other than age.”

228

Background

In a revised employee pay plan, the City of Jackson in Mississippi increased the salaries of all police officers and dispatchers. Employees with less than five years of service received greater raises than ones with more seniority. In this police department, most officers over the age of 40 had served for more than five years. Azel Smith and a group of other department employees filed suit under the ADEA, claiming disparate impact and arguing that the City and police department unintentionally discriminated against them based on their age group. The District Court and

Fifth Circuit Court of Appeals The United States Court of Appeals for the Fifth Circuit (in case citations, 5th Cir.) is one of the 13 United States courts of appeals. It has appellate jurisdiction over the U.S. district courts in the following federal judicial districts: ...

ruled that disparate impact claims were not available under the ADEA."Smith v. City of Jackson, Mississippi." ''Oyez,''www.oyez.org/cases/2004/03-1160. Accessed 26 Aug. 2023.

Result

In a 5–3 decision, the Court held that disparate impact claims are available under the ADEA, similar to such claims under

Title VII of the Civil Rights Act of 1964 The Civil Rights Act of 1964 () is a landmark civil rights and labor law in the United States that outlaws discrimination based on race, color, religion, sex, and national origin. It prohibits unequal application of voter registration requi ...

as set forth in ''Griggs'' v. ''Duke Power Co.'' The Court reasoned that the ADEA and Title VII contain identical language concerning unlawful discrimination. However, the ADEA is narrower and permits “otherwise prohibited” actions “where the differentiation is based on reasonable factors other than age.” The Court further ruled that the petitioners in this case failed to set forth a valid disparate impact claim, as they did not identify any specific test or practice in the pay plan that had an adverse impact on older employees. The Court noted that the City’s explanation that the differentiation in raise proportions was based on its goal to make junior officers’ salaries more competitive in the market provided “reasonable factors other than age.”

References

External links

* {{Caselaw source, case=''Smith v. City of Jackson'', {{ussc, 544, 228, 2005, el=no, justia=https://supreme.justia.com/cases/federal/us/544/228/, oyez=https://www.oyez.org/cases/2004/03-1160, cornell=https://www.law.cornell.edu/supct/html/03-1160.ZS.html, vlex=https://case-law.vlex.com/vid/smith-v-city-of-890932738, googlescholar=https://scholar.google.com/scholar_case?case=9749401509062904417&q=Smith+v.+City+of+Jackson,+544+U.S.+228+(2005)&hl=en&as_sdt=8006, leagle=https://www.leagle.com/decision/2005772544us2281763, other_source1=casetext, other_url1=https://casetext.com/case/smith-v-city-of-jackson United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court Anti-discrimination case law in the United States 2005 in United States case law United States employment discrimination case law Ageism case law

Background

Result

See also

References

External links