Simpson v. Midland-Ross Corp.

Summary

The Sixth Circuit considered an age-discrimination claim brought under the federal Age Discrimination in Employment Act and Michigan’s Elliott-Larsen Act after Midland-Ross terminated Frederick Simpson during a reduction in force. The court held that Simpson’s statistical and performance-related evidence was insufficient to show that the employer’s stated nondiscriminatory reasons were pretextual or that age motivated the discharge. It therefore reversed the district court’s denial of Midland-Ross’s motion for judgment notwithstanding the verdict.

Holdings

1. Simpson's evidence was insufficient to permit a reasonable jury to find that Midland-Ross's stated reasons for his discharge were pretextual or that age was the motivating factor in the discharge.
2. Statistical evidence has probative value only when its methodology and explanatory power permit a reasonable inference of discrimination; generalized age figures, small samples, and uncontextualized hiring or departure statistics are insufficient by themselves.
3. The McDonnell Douglas framework is not to be applied mechanically or rigidly in ADEA discharge cases; the ultimate question after a trial on the merits is whether the plaintiff proved intentional age discrimination by a preponderance of the evidence.

Questions Presented

1. Whether the evidence was sufficient to support a jury finding that Midland-Ross discharged Simpson because of his age under the ADEA and Michigan's Elliott-Larsen Act.
2. Whether the district court erred in denying Midland-Ross's motion for judgment notwithstanding the verdict.
3. Whether the court needed to reach the parties' other challenges concerning jury instructions, damages, prejudgment interest, and the timeliness of Simpson's cross-appeal.

Disposition

reversed