Supreme Court of the United States
O’connor v. Consolidated Coin Caterers Corp.
April 1, 1996517 U.S. 308
Summary
Justice Scalia delivered the unanimous opinion holding that an ADEA plaintiff need not show replacement by someone outside the protected age group to establish a prima facie case under the McDonnell Douglas framework. The ADEA prohibits discrimination because of age, not protected-class membership; replacement by a substantially younger person is therefore more probative than replacement by someone under 40. Replacement by an insignificantly younger worker does not itself support the necessary inference of age discrimination. The Court assumed without deciding that the McDonnell Douglas framework applies to ADEA claims, reversed the Fourth Circuit’s judgment, and remanded. There were no separate opinions.
Holding
- Whether replacement by someone outside the ADEA’s protected age group is a required element of a prima facie case.. Assuming the McDonnell Douglas framework applies to ADEA claims, replacement by someone outside the protected age group is not a proper element of the prima facie case.
- Whether the replacement worker’s relative age supports an inference of age discrimination.. Replacement by an insignificantly younger worker does not itself create an inference of age discrimination; a substantially younger replacement is a more reliable indicator than a replacement outside the protected class.
Docket 95-354
Cited authorities
- CA11
- CA10
- 81 Stat. 602
- 29 U.S.C. § 621
- 42 U.S.C. § 1983
- 29 U.S.C. § 623
Cited by
- Mendoza v. Macy's Inc.
- Mary Shea Knight v. Avon Products, Inc.
- Robert H. Locke v. W.R. Grace & Co. - Conn.
- E. Bernard Plante v. Shawmut Bank, N.A.
- Jerry L. Worlds v. Thermal Industries, Inc. and Michael Law
- Audrey P. Dyjak v. Baystate Health Systems, Inc.
- Kuznarowis v. Tobey Hospital
- Higgins v. State Street Corporation