Smith v. City of Jackson, 544 U.S. 228 (2005)

In Smith v. City of Jackson, the underlying dispute arose when police and public safety officers employed by the City of Jackson, Mississippi, challenged a pay plan adopted by the City on October 1, 1998. This plan aimed to provide salary increases to all City employees to attract and retain qualified personnel, maintain competitiveness, and ensure equitable compensation. However, when the plan was revised on May 1, 1999, it resulted in proportionately greater raises for less tenured officers compared to those with more seniority. Most of the older officers, particularly those over the age of 40, had longer tenures and thus received smaller raises, leading to claims of age discrimination under the Age Discrimination in Employment Act of 1967 (ADEA). The procedural history of the case began with the petitioners filing suit against the City, asserting both disparate-treatment and disparate-impact claims under the ADEA. The District Court granted summary judgment in favor of the City on both claims. However, the Court of Appeals found that while the ruling on the disparate-treatment claim was premature due to the need for further discovery regarding intent, it affirmed the dismissal of the disparate-impact claim. The majority opinion of the appellate court concluded that such claims were not permissible under the ADEA, a decision that was contested by a dissenting judge. The Supreme Court granted certiorari to address whether the ADEA allows for disparate-impact claims, ultimately affirming the lower court's dismissal of the claim while recognizing the possibility of such claims under the ADEA. The case also highlighted the historical context of the ADEA, noting that during the deliberations for the Civil Rights Act of 1964, Congress had considered but ultimately rejected amendments to include older workers as a protected class against employment discrimination. This context was significant in understanding the legislative intent behind the ADEA and its application to the claims raised by the petitioners.

Whether the "disparate-impact" theory of recovery, as established in Griggs v. Duke Power Co., is cognizable under the Age Discrimination in Employment Act of 1967 (ADEA).

The judgment is reversed.