Reeves v. Sanderson Plumbing Products, Inc.

Background

Roger Reeves, a 57-year-old longtime factory supervisor, was fired after a company audit found alleged timekeeping problems. He sued under the Age Discrimination in Employment Act, saying he was fired because of his age. At trial the jury sided with Reeves, but the court of appeals overturned the verdict, holding Reeves had not proven age was the real reason for his firing.

Reasoning

The Court addressed whether a worker who makes a basic showing of discrimination and presents enough evidence for a reasonable jury to disbelieve the employer’s explanation can still win. The Court said yes: when a plaintiff proves a prima facie case (a basic initial showing) and the jury could reject the employer’s stated reason, that combination can support a finding of intentional discrimination. The Court explained judges deciding motions for judgment as a matter of law must review the whole record, draw reasonable inferences for the jury, and may not weigh credibility. Applying that rule here, the Court concluded Reeves had sufficient evidence of falsified explanations and age bias, so the jury verdict should stand.

Real world impact

The decision makes clear that employees can avoid being thrown out of court simply by showing (1) a basic discrimination case and (2) evidence that the employer’s stated reason is not believable. Employers are not automatically entitled to judgment when their explanation is disputed; juries may infer discrimination from a false explanation. This ruling resolves a split among appeals courts and guides trial judges on reviewing evidence.

Dissents or concurrances

Justice Ginsburg wrote separately to note the same outcome and suggested that future cases might further refine when additional evidence beyond those two categories is required.