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O’Connor v. Consolidated Coin Caterers,
517 U.S. 308 (1996)
At age 56, O’Connor was fired and replaced by a 40-year-old. He filed
a lawsuit in federal district court. The court granted the Defendant’s motion
for summary judgment, and the Plaintiff appealed. The Fourth Circuit affirmed
based on its own rule that a plaintiff can only make out a prima facie case under
the McDonnell Douglas framework if she can prove that she was replaced
by someone outside the protected class of persons forty years of age and older.
The Supreme Court took this case from the Fourth Circuit to make clear that proving
that a plaintiff was replaced by someone younger than 40 is not a requirement
of making out a prima facie case of discrimination under the McDonnell Douglas
test. In so holding, the Supreme Court made several statements which redefined
the parameters of the prima facie case.
The Court said that under the test there must be a logical connection between
each element of the prima facie case and the illegal discrimination. The Court
found no such connection in the requirement imposed by the Fourth Circuit. The
Court held that to require a plaintiff to show that the person hired in his stead
was outside the protected class would create a situation which the ADEA did not
intend. Indeed, it would create a situation where it would be acceptable to discriminate
on the basis of age so long as the employee fired was replaced by a person age
40 or older. The Court went on to say that some courts had been possibly induced
to adopt the above-mentioned requirement in order to avoid creating a prima facie
case on the basis of very thin evidence; such as where a 68-year-old had been
replaced by a 65-year-old. The Court said that in its view, however, the proper
solution to the problem lies, not in making an irrelevant factor an element of
the prima facie case, but rather in recognizing that the prima facie case requires
evidence adequate to create an inference that an employment decision was based
on an illegal discriminatory criterion.
The Supreme Court in O’Connor remanded the case back to the Fourth
Circuit for proceedings consistent with its opinion.
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