Federal Express Corp. v. Holowecki, 552 U.S. 389 (2008)
Primary Holding
A charge alleging unlawful age discrimination under the Age Discrimination in Employment Act (ADEA) is valid if it is sufficiently clear to put the Equal Employment Opportunity Commission (EEOC) on notice of the alleged violation, regardless of whether it strictly adheres to the formal requirements outlined in the agency's regulations.
In the case of Federal Express Corp. v. Holowecki, a group of older employees claimed that FedEx's performance programs unfairly discriminated against them based on their age. The Supreme Court ruled that as long as an employee's complaint to the Equal Employment Opportunity Commission (EEOC) clearly indicates they believe they've faced age discrimination, it doesn't have to meet strict formal requirements to be valid. This decision helps protect consumers by ensuring that older workers can pursue their rights without being blocked by technicalities, making it relevant for anyone who feels they've been discriminated against at work due to their age.
AI-generated plain-language summary to help you understand this case
In Federal Express Corp. v. Holowecki, 552 U.S. 389 (2008), the dispute arose from two performance-based programs implemented by Federal Express Corporation (FedEx) in 1994 and 1995, known as "Best Practice Pays" (BPP) and "Minimum Acceptable Performance Standards" (MAPS). These programs linked couriers' compensation and job security to specific performance metrics, such as the number of daily stops. Fourteen current and former FedEx couriers over the age of 40 filed a lawsuit in the United States District Court for the Southern District of New York on April 30, 2002, claiming that these programs constituted age discrimination in violation of the Age Discrimination in Employment Act (ADEA). The plaintiffs alleged that BPP and MAPS were designed to push older workers out of the company before they could retire, thereby favoring younger employees. The procedural history of the case involved a challenge to the timeliness of one plaintiff's claim, Patricia Kennedy. FedEx moved to dismiss her lawsuit on the grounds that she had failed to file a charge with the Equal Employment Opportunity Commission (EEOC) at least 60 days prior to initiating her suit, as mandated by 29 U.S.C. §626(d). In response, Kennedy asserted that she had filed a valid charge with the EEOC on December 11, 2001, using EEOC Form 283. The case ultimately reached the Supreme Court on a writ of certiorari to resolve the conflicting interpretations of what constitutes a "charge" under the ADEA, as there were inconsistencies among the Courts of Appeals regarding the definition and implications of such filings. The background context of this case highlights the complexities surrounding the enforcement of the ADEA, particularly in relation to the EEOC's procedures and the statutory requirements for filing discrimination claims. The lack of a clear statutory definition for "charge" under the ADEA has led to varying interpretations, complicating the process for employees seeking legal recourse for age discrimination. The Supreme Court's decision aimed to clarify these issues and establish a more uniform understanding of the requirements for filing a charge with the EEOC in age discrimination cases.
Whether a submission of an EEOC Form 283 constitutes a valid charge of age discrimination under the Age Discrimination in Employment Act, thereby satisfying the requirement to file a charge with the EEOC before initiating a lawsuit.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- November 6, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Kennedy
- Damages Awarded
- N/A
- Data Quality
- high
Meacham v. Knolls Atomic Power Laboratory, 554 U.S. 84 (2008)
Consumer WonAn employer defending against a disparate-impact claim under the Age Discrimination in Employment Act must not only produce evidence supporting its defense based on reasonable factors other than age but must also persuade the factfinder of the merit of that defense.
Smith v. City of Jackson, 544 U.S. 228 (2005)
Consumer LostThe Age Discrimination in Employment Act (ADEA) allows for recovery under a "disparate-impact" theory of discrimination, similar to that established in Griggs v. Duke Power Co., but the plaintiffs must still demonstrate a valid disparate-impact claim to succeed.
Sprint/United Management Co. v. Mendelsohn, 552 U.S. 379 (2008)
Mixed OutcomeThe Supreme Court held that evidence of age discrimination by nonparties is neither per se admissible nor per se inadmissible under the Federal Rules of Evidence; rather, its admissibility must be determined based on a relevant inquiry into its probative value and potential prejudicial effect.
Gomez-Perez v. Potter, 553 U.S. 474 (2008)
Consumer WonA federal employee who experiences retaliation for filing a complaint of age discrimination may assert a claim under the federal-sector provision of the Age Discrimination in Employment Act of 1967 (ADEA).