Kentucky Retirement Systems v. EEOC, 554 U.S. 135 (2008)
Primary Holding
Kentucky's retirement system does not discriminate against employees based on age under the Age Discrimination in Employment Act (ADEA) because the benefits provided to disabled employees are based on their years of service and not their age at the time of disability.
In the case of Kentucky Retirement Systems v. EEOC, the Supreme Court decided that Kentucky's retirement plan does not unfairly discriminate against older workers who become disabled. This matters because it means that benefits for disabled employees are based on their years of service rather than their age, ensuring that all workers are treated fairly regardless of how old they are when they become disabled. This case is relevant for anyone in Kentucky who is concerned about retirement benefits and age discrimination, especially if they are in a hazardous job and face disability.
AI-generated plain-language summary to help you understand this case
In Kentucky Retirement Systems v. EEOC, the underlying dispute arose from the Commonwealth of Kentucky's retirement plan for state and county employees in hazardous positions, such as police officers and firefighters. The plan allowed these employees to retire and receive normal retirement benefits after either 20 years of service or after 5 years of service if they reached the age of 55. Additionally, the plan provided for disability retirement benefits for employees who became seriously disabled before qualifying for normal retirement. The Equal Employment Opportunity Commission (EEOC) contended that the retirement plan discriminated against older workers by treating disabled employees who became eligible for retirement based on age less favorably than those who became disabled before reaching retirement eligibility. The procedural history of the case began when the EEOC filed a charge against Kentucky Retirement Systems, asserting that the retirement plan's provisions violated the Age Discrimination in Employment Act (ADEA). The case was brought before the United States Court of Appeals for the Sixth Circuit, which ruled in favor of the EEOC. Kentucky Retirement Systems then sought a writ of certiorari, leading to the Supreme Court's review of the case. The relevant background context includes the specific provisions of Kentucky's retirement plan that allowed for the calculation of benefits based on imputed years of service for disabled employees. This calculation was designed to ensure that disabled workers received benefits comparable to those who could retire normally. The Supreme Court was tasked with determining whether the plan's treatment of disabled employees constituted age discrimination under the ADEA, ultimately concluding that it did not.
Whether Kentucky's retirement system discriminates against employees who become disabled after reaching retirement age, in violation of the Age Discrimination in Employment Act of 1967.
The judgment of the Court of Appeals is affirmed and the case is remanded for a determination whether the State can assert a cost-justification defense.
- Court
- Supreme Court
- Decision Date
- January 9, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
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.
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.
Federal Express Corp. v. Holowecki, 552 U.S. 389 (2008)
Consumer WonA 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.
LaRue v. DeWolff, Boberg & Associates, Inc., 552 U.S. 248 (2008)
Consumer WonA participant in a defined contribution pension plan may sue a fiduciary under §502(a)(2) of the Employee Retirement Income Security Act (ERISA) for breaches of fiduciary duty that impair the value of their individual account, allowing for recovery that benefits the individual rather than solely the plan as a whole.