Lorillard v. Pons
Headline: Court rules that employees suing for lost wages under the Age Discrimination law can demand jury trials, shifting back-pay decisions in age-bias cases from judges to juries in many workplace disputes.
Holding: In a private ADEA suit for lost wages, employees have a statutory right to demand a jury trial because Congress incorporated the Fair Labor Standards Act’s procedures and remedies into the ADEA.
- Employees suing for ADEA back pay can demand jury trials.
- Employers may face jury determinations of lost-wage awards.
- Leaves open jury rights for liquidated damages and constitutional questions.
Summary
Background
A former employee sued her previous employer, saying she was fired because of her age. She asked for reinstatement, back pay, liquidated damages, attorney fees, and a jury trial on factual issues. The trial court struck her jury demand, but the Court of Appeals reversed, and the Supreme Court agreed to decide whether the law gives a jury right for lost wages.
Reasoning
The Justices first looked at the text and structure of the Age Discrimination in Employment Act rather than the Constitution. The Court found Congress had directed that ADEA claims be enforced under the same remedies and procedures as the Fair Labor Standards Act. Because courts had long allowed jury trials for private wage claims under that older law and because Congress used the word "legal" relief, the Court concluded Congress intended a jury option for ADEA lost-wage claims. The Court therefore affirmed the appeals court and did not decide the separate constitutional (Seventh Amendment) question.
Real world impact
Employees who sue employers under the ADEA for back pay can demand jury trials on factual claims about lost wages. Employers defending age-discrimination pay claims should expect jury factfinding in many cases. The Court left open related issues, including whether liquidated damages are triable to a jury and the separate constitutional argument.
Dissents or concurrances
The opinion notes that one appellate judge wrote a separate concurring opinion and that one Justice did not participate, but no dissent altered the Court’s statutory conclusion.
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