Reeves v. Sanders Plumbing Products, Inc.,
120 S.Ct. 2097 (2000)

In this case a 57-year-old and a 35-year-old were fired because, as the company put it, of several errors and misrepresentations they had made on internal reports. The Plaintiff, Reeves, contended that he was fired because of his age. He supported that allegation with evidence that he had accurately and honestly filled out all paperwork and that the supervisor who orchestrated his termination had demonstrated, through his comments, an age-based animus. Reeves brought suit in federal court, where his claim was heard by a jury and a verdict was entered in his favor. The Fifth Circuit reversed the district court, holding that the Defendant was due a judgment as a matter of law because Reeves had not presented sufficient evidence for the jury to have found that he was fired because of his age. In so holding, the court weighed the additional evidence of discrimination introduced by Reeves against the other circumstances surrounding his discharge, including the fact that the supervisor’s age-based comments were not made in the direct context of Reeves’ termination and the fact that there was no allegation that the other individual recommended for firing along with Reeves, was so recommended because of his age. The Plaintiff appealed, and the Supreme Court took the case and reversed the Fifth Circuit.

Specifically, the high Court held that a plaintiff’s prima facie case of discrimination, combined with sufficient evidence for a reasonable fact finder to reject the employer’s nondiscriminatory explanation for its decision, may be adequate to sustain a finding of liability for intentional discrimination under the ADEA. Since Reeves had introduced such evidence, and since on summary judgment all evidence must be viewed in favor of the non-moving party, the Supreme Court reversed the Fifth Circuit and reinstated the holding of the district court for the Plaintiff.

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