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McKennon v. Nashville Banner Publishing Co.,
115 S.Ct. 879 (1995)
After 30 years of service, the Plaintiff, Christine McKennon, was discharged
as part of a workforce reduction plan necessitated by cost considerations. She
was 62 years old when she lost her job and sued for age discrimination. The Plaintiff
filed in district court, seeking a variety of legal and equitable remedies available
under the ADEA, including backpay. During the depositions for the trial, it came
out that McKennon had copied several confidential documents and taken them home
with her and shown them to her husband. Representatives of the Defendant said
that they would have fired her immediately had they known she had done this. The
district court granted summary judgment for the Nashville Banner, holding that
the Plaintiff’s conduct was grounds for her termination and that no remedy
was available to her under the ADEA. The Sixth Circuit affirmed.
The Supreme Court, in reversing, held that a violation of the ADEA could not
be so altogether disregarded. The Court said that, although equitable relief was
usually barred to a wrongdoing plaintiff, that will not be the case in ADEA cases,
where Congress has authorized broad equitable relief to serve important national
policies. The Court made clear, however, that an employee’s misconduct will
not be held irrelevant once it is proven to be of a severity that would have warranted
termination at the time of the wrongdoing. The Court held that the proper boundaries
of remedial relief, in the general class of cases where, after termination, it
is discovered that the employee has engaged in wrongdoing, must be addressed on
a case-by-case basis. The Court set out a general rule that, in cases of this
type, neither frontpay or reinstatement is an appropriate remedy. The Court held
that backpay, calculated from the date of the unlawful discharge to the date the
new information was discovered, is appropriate in some cases of this nature. Finally,
the Supreme Court left the lower courts free to consider extraordinary equitable
circumstances that affect the legitimate interests of either party.
The Supreme Court remanded the case to the Sixth Circuit for proceedings consistent
with its opinion.
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