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Meacham v. Knolls Atomic Power Lab.
United States Supreme Court
554 U.S. 84 (2008)
Knolls Atomic Power Lab. (Knolls) (defendant), a private company, performed maintenance work on the federal government’s nuclear-powered warships. Due to decreasing demands related to the end of the Cold War, Knolls was ordered to cut back its work force. About 100 Knolls employees opted to accept buyout offers, but around 30 jobs remained that Knolls needed to cut. To determine which of the remaining employees would be involuntarily laid off, Knolls instructed its managers to score employees on performance, flexibility, and critical skills. Those scores were added, plus points given for years of service, to decide which employees would be cut. Thirty of the 31 employees ultimately let go were age 40 or older, and 28 of those employees (plaintiffs) sued Knolls, alleging unlawful disparate treatment and disparate-impact discrimination under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. §§ 621-34. In attempting to make a prima facie showing, the plaintiffs relied on expert testimony that such extreme statistical disparities were not likely coincidental and that the scores given at the discretion of managers were most strongly linked to the skewed statistical outcomes. A jury found in favor of the plaintiffs on their disparate-impact claim but not their disparate-treatment claim. After multiple appeals, the plaintiffs ultimately sought review from the United States Supreme Court.
Rule of Law
Holding and Reasoning (Souter, J.)
Concurrence (Scalia, J.)
Concurrence/Dissent (Thomas, J.)
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