Meacham v. Knolls Atomic Power Laboratory, 554 U.S. 84 (2008)

In Meacham v. Knolls Atomic Power Laboratory, the underlying dispute arose from a workforce reduction at Knolls Atomic Power Laboratory (KAPL), a contractor for the U.S. government involved in maintaining nuclear-powered warships. Following a directive to reduce its workforce due to changing demands after the Cold War, KAPL laid off 31 salaried employees, of whom 30 were aged 40 or older. The laid-off employees, led by Clifford B. Meacham, alleged that KAPL's layoff process was discriminatory under the Age Discrimination in Employment Act (ADEA), claiming both disparate-treatment and disparate-impact based on age. They argued that the criteria used for layoffs, which included subjective scoring on performance, flexibility, and critical skills, disproportionately affected older employees. The procedural history of the case began with the filing of a lawsuit by Meacham and other affected employees, who presented their claims in the U.S. District Court. The jury found in favor of the plaintiffs on the disparate-impact claim but not on the disparate-treatment claim. The Court of Appeals for the Second Circuit affirmed the jury's decision, applying a burden-shifting framework from a prior Supreme Court case. KAPL then sought certiorari from the Supreme Court, which vacated the appellate judgment and remanded the case for further proceedings in light of a subsequent Supreme Court decision that clarified standards for disparate-impact claims. The relevant background context includes the ADEA's provision that allows employers to defend against disparate-impact claims by demonstrating that their actions were based on "reasonable factors other than age" (RFOA). The case raised critical questions about the burden of proof required for employers in such claims, specifically whether they must only present evidence of their defense or also persuade the factfinder of its validity. This case is significant in the interpretation of age discrimination laws and the standards that employers must meet when implementing workforce reductions that may disproportionately affect older employees.

Whether an employer facing a disparate-impact claim under the Age Discrimination in Employment Act must not only produce evidence for a defense based on reasonable factors other than age but also persuade the factfinder of its merit.

The judgment of the Court of Appeals is vacated.