Robert I. Ridenour v. The Lawson Company, a Consolidated Foods Company

Summary

The Sixth Circuit reviewed a jury verdict for Robert I. Ridenour in an Age Discrimination in Employment Act action against The Lawson Company. The court held that Ridenour presented insufficient evidence to establish pretext for Lawson's stated nondiscriminatory reasons for declining to promote him and terminating his employment during a restructuring. The court reversed the district court's judgment; Judge Keith dissented.

Holdings

1. Lawson was entitled to judgment notwithstanding the verdict because, even viewing the evidence and reasonable inferences in Ridenour's favor, the evidence pointed so strongly toward Lawson's legitimate, nondiscriminatory reasons that reasonable minds could not conclude that Lawson's actions were motivated by age discrimination.
2. An employer that reduces its workforce for economic reasons incurs no duty to transfer an employee to another position within the company.

Questions Presented

1. Whether the evidence, viewed in the light most favorable to Ridenour, permitted a reasonable jury to find that Lawson's refusal to promote him and subsequent discharge were motivated by age discrimination under the ADEA.
2. Whether Lawson was entitled to judgment notwithstanding the verdict because Ridenour failed to produce probative evidence that Lawson's legitimate, nondiscriminatory reasons were pretextual.
3. Whether an employer conducting an economically motivated workforce reduction had a duty to transfer Ridenour to a lower-level position.

Disposition

reversed