Stephenson v. Hotel Employees & Restaurant Employees Union Local 100 of the AFL-CIO

Summary

The New York Court of Appeals addressed an age-discrimination claim brought by two former union employees who alleged they were terminated because of their ages. The court held that the defendants presented legitimate, nondiscriminatory reasons for the terminations related to alleged corruption and that the plaintiffs failed to prove those reasons were pretextual. The court affirmed the Appellate Division’s order setting aside the jury verdict and dismissing the complaint.

Holdings

1. A plaintiff alleging age discrimination must establish a prima facie case, after which the defendant must produce a legitimate, nondiscriminatory reason for the adverse action, and the plaintiff must then prove by a preponderance of the evidence that the stated reason was pretextual; the ultimate burden of persuasion remains with the plaintiff.
2. The evidence was legally insufficient to support the jury verdicts because defendants presented legitimate reasons for the terminations and plaintiffs failed to prove those reasons were pretextual.
3. The certified question should not be answered because it was unnecessary to the disposition.

Questions Presented

1. Whether the Appellate Division properly set aside the jury verdicts and dismissed plaintiffs' age-discrimination claims under New York Executive Law § 296.
2. Whether plaintiffs established that defendants' stated, legitimate reasons for terminating them were pretextual.
3. Whether the certified question should be answered.

Disposition

affirmed