Equal Employment Opportunity Commission v. Wyoming

As part of Title VII of the Civil Rights Act of 1964, the United States secretary of labor was ordered to study age-based employment discrimination. A year later, the secretary submitted a report finding that many employers imposed upper age limits on their employees but that no significant empirical data supported the use of these age limits. To the contrary, the data showed that older workers tended to perform at least as well as younger workers and that using age limits harmed the economy, the government, and older individuals. Specifically, age limits harmed the economy by causing a loss of productive workers. Next, the age limits harmed the government by increasing the use of governmental services such as unemployment and Social Security benefits. Finally, the age limits harmed older individuals by denying them the economic and psychological benefits of being able to engage in productive work. To reduce these harms, in 1967, Congress passed the Age Discrimination in Employment Act (ADEA), which prohibited private employers of a certain size from discriminating against workers between the ages of 40 and 65 on the basis of their age. In 1974, the ADEA was expanded to cover local-, state-, and federal-government employers. In 1978, the ADEA was expanded to cover workers up to age 70. Several lawsuits were filed claiming that the ADEA’s application to local- and state-government employers violated the United States Constitution. Although multiple courts initially upheld the statute, a federal district court in Wyoming ruled that the ADEA could not be constitutionally applied to local and state governments in their roles as employers. The United States Supreme Court agreed to review the issue.