Equal Employment Opportunity Commission v. Manville Sales Corporation

Charles Mitte (plaintiff) was terminated from his sales-representative position by Manville Sales Corporation (Manville) (defendant). Mitte and the Equal Employment Opportunity Commission (the commission) (plaintiff) filed actions under the Age Discrimination in Employment Act (ADEA) against Manville in federal district court for improper age discrimination. Mitte argued that he performed better in sales during the past two years than Manville’s younger sales representatives. Manville argued that it was forced to terminate a sales representative due to financial issues and that Mitte was the least effective representative, had difficulty interacting with certain customers and with high-volume accounts, and was inflexible with new opportunities. At trial, Mitte and the commission sought to introduce into evidence the commission’s letter of violation. The letter contained the commission’s conclusion from its investigation that Manville had engaged in improper age discrimination. The district court excluded the letter under Federal Rule of Evidence 403 (Rule 403). The jury returned a verdict in favor of Manville. Mitte and the commission appealed on the ground that the district court had abused its discretion by excluding the letter. The commission argued that the Fifth Circuit had previously held that a letter of reasonable cause issued by the commission was admissible because it was highly probative, with its probative value outweighing any prejudicial effect.