John T. Graham v. F.B. Leopold Company, Inc.

Summary

The Third Circuit considered an Age Discrimination in Employment Act claim brought by a 53-year-old former employee who was discharged during a supervisory workforce reduction and replaced by a younger employee. The court held that testimony concerning statements by a company official could support a reasonable inference of age discrimination and that summary judgment for the employer was improper. Judge Adams dissented, concluding that the evidence did not reasonably support an inference that age motivated the termination.

Holdings

1. The three-step burden-shifting procedure developed for Title VII claims applies in an ADEA action.
2. Summary judgment for Leopold was improper because the record, viewed in Graham's favor, permitted a jury reasonably to infer that the discharge was motivated by age discrimination.

Questions Presented

1. Whether Graham's deposition testimony and the surrounding circumstances created a genuine issue of material fact from which a jury could reasonably infer that Leopold discharged him because of his age.
2. Whether the district court properly granted summary judgment after finding that Graham had not shown that Leopold's legitimate, nondiscriminatory explanation was pretextual.
3. Whether the McDonnell Douglas burden-shifting framework applies to ADEA discrimination claims.

Disposition

reversed_and_remanded