Sprint/United Management Co. v. Mendelsohn, 552 U.S. 379 (2008)

In Sprint/United Management Co. v. Mendelsohn, the underlying dispute arose when Ellen Mendelsohn, who was employed by Sprint from 1989 until her termination in 2002 as part of a company-wide reduction in force, filed a lawsuit against Sprint alleging age discrimination under the Age Discrimination in Employment Act (ADEA). To support her claim, Mendelsohn sought to introduce testimony from five former Sprint employees who claimed they had experienced age discrimination from supervisors at Sprint. These witnesses reported various instances of discriminatory remarks and actions, including negative evaluations and hiring practices that allegedly favored younger employees. However, none of these witnesses had worked in Mendelsohn's department or under the same supervisors involved in her termination. The procedural history of the case began when the District Court excluded the testimony of the five former employees, ruling that it was irrelevant to Mendelsohn's specific situation since they were not "similarly situated" to her. Sprint argued that the testimony should be excluded based on Federal Rules of Evidence 401 and 403, asserting that the evidence lacked relevance and could unfairly prejudice the jury. The Court of Appeals later reversed this decision, concluding that the District Court had improperly applied a per se rule against the admission of the evidence and remanded the case for further consideration. The Supreme Court granted certiorari to address whether the Federal Rules of Evidence required the admission of the testimony in question. The Court ultimately determined that the evidence was neither automatically admissible nor inadmissible, and since it was unclear if the District Court had applied a per se rule, the judgment of the Court of Appeals was vacated. The case was remanded for the District Court to conduct a proper inquiry under the appropriate standards of relevance and admissibility.

Whether the Federal Rules of Evidence require the admission of testimony from nonparties alleging age discrimination when such testimony does not come from employees who were similarly situated to the plaintiff in the context of an age discrimination case.

The judgment is vacated and the case is remanded with instructions to have the District Court clarify the basis for its evidentiary ruling under the applicable Rules.