Aguayo v. R.J. Reynolds Tobacco Co.

Summary

The United States District Court for the District of Puerto Rico granted R.J. Reynolds Tobacco Company's motion for summary judgment in an age-discrimination action brought under the ADEA and Puerto Rico Law 100. The court held that although the plaintiff established a prima facie case, he failed to show that the employer's stated nondiscriminatory reason for his discharge was pretextual. The court dismissed both the federal and pendent territorial claims.

Holdings

1. Aguayo established a prima facie case because he was within the protected age group, had satisfactory performance evaluations, was discharged, and was replaced by a younger employee.
2. Aguayo failed to show that R.J. Reynolds's legitimate, nondiscriminatory explanation for his discharge was pretextual; challenging the quality of the employer's business decision and merely casting doubt on the explanation were insufficient.
3. The Law 100 claim failed because the employer's evidence rebutted the statutory presumption that Aguayo was discharged without just cause and satisfied its burden of production and persuasion.

Questions Presented

1. Whether the employer was entitled to summary judgment on Aguayo's ADEA age-discrimination claim after articulating a legitimate, nondiscriminatory reason for the discharge.
2. Whether Aguayo's evidence was sufficient to establish that the employer's stated reason for discharge was a pretext for age discrimination.
3. Whether the employer was entitled to summary judgment on the Puerto Rico Law 100 age-discrimination claim after rebutting the statutory presumption of discharge without just cause.

Disposition

dismissed