Summary
The Seventh Circuit affirmed a jury verdict for seven former employees who claimed that Mayfair Molded Products violated the Age Discrimination in Employment Act by terminating them when it closed its rubber division. The court held that substantial evidence supported the jury’s finding that age was a determining factor, including the company’s refusal to permit interdepartmental seniority bumping and its subsequent hiring of younger workers.
Topics
Practice areas
Questions Presented
- Whether substantial evidence supported the jury's finding that age was a determining factor in Mayfair's decision to terminate the plaintiffs in a reduction-in-force situation.
- Whether the district court properly denied Mayfair's motion for judgment notwithstanding the verdict.
- Whether the district court properly denied Mayfair's motion for a directed verdict.
Holdings
- Substantial evidence supported the jury's finding that age was a determining factor in Mayfair's termination decisions.
- The district court properly denied Mayfair's motion for judgment notwithstanding the verdict because the evidence, viewed favorably to the plaintiffs, was sufficient to support the jury's verdict.
- The district court properly denied Mayfair's motion for a directed verdict because the plaintiffs presented substantial evidence from which the jury could reasonably find that age was a determining factor in their terminations.
- To prevail under the ADEA, a plaintiff must prove that age was a determining factor in the adverse employment action, meaning the plaintiff would not have been discharged but for the employer's discriminatory motive.
Key quotations
“"Any conflicts in the evidence must be resolved in favor of the resisting party, and every permissible inference favoring that party which can be drawn from the evidence must be drawn."” (¶ 13)
“"must prove not that age was the sole factor motivating the employer to discharge him but that age was a 'determining factor,' in the sense that he would not have been discharged 'but for' his employer's motive to discriminate against him because of his age."” (¶ 16)
“The jury reasonably could have found that, while the decision to close the rubber division was not itself based on age discrimination, Mayfair's refusal to allow the discharged workers to bump others with less seniority in the plastics division and Mayfair's hiring of younger workers when jobs became available shortly after the plaintiffs were discharged constituted discrimination based on age.” (¶ 22)
Factual background
Mayfair closed its rubber division in July 1983 because of decreased demand and declining profitability, terminating thirty employees except for three workers with special skills who were transferred to the plastics division. The seven plaintiffs, all between ages forty and sixty and possessing seven to fifteen years of seniority, were among those terminated. The plaintiffs presented evidence that they were qualified for positions in other divisions, that Mayfair had previously used interdepartmental seniority and bumping practices, and that Mayfair hired younger workers for positions that became available shortly after the terminations.
Procedural history
The district court denied Mayfair's motion for summary judgment. After trial, the jury returned a verdict for the plaintiffs. The district court denied Mayfair's motions for a directed verdict, judgment notwithstanding the verdict, and a new trial; on appeal, Mayfair pursued the directed-verdict and judgment-notwithstanding-the-verdict issues. The Seventh Circuit affirmed.