Hardin v. Pitney-Bowes, Inc.

Background

A worker sued a company under the Age Discrimination in Employment Act, saying he was unlawfully fired. The trial court granted the company’s motion for summary judgment, and the Sixth Circuit affirmed. Chief Judge Edwards dissented at the appeals court. The Supreme Court denied review, and Justice Rehnquist wrote a dissent saying he would have granted review.

Reasoning

The central question Justice Rehnquist described was whether a judge may decide a case before trial when the employer’s motive and intent are disputed. He argued that questions of credibility, motive, and intent should go to a jury and cannot be resolved on motions for summary judgment. Rehnquist cited Arnstein v. Porter and recent defamation decisions that questioned deciding state-of-mind issues before trial. He criticized this Court’s earlier statement in Butz v. Economou that immunity defenses could justify summary dismissal, calling that view wrong when motive or intent is at issue, and said the worker raised a triable issue of fact.

Real world impact

Because the Court declined to hear the case, the lower-court judgment for the company stands and the worker does not get a full trial here. Rehnquist warned that allowing summary judgment where motive is disputed risks wrongly resolving trials and may force more cases to go to trial if courts follow his view. He wrote that this problem could mean even frivolous lawsuits against top-level federal officials may have to be tried. The denial is not a final ruling on the discrimination claim’s merits.

Dissents or concurrances

Justice Rehnquist dissented from the denial of review. He emphasized that summary judgment is inappropriate when motive and intent are at issue and would have granted plenary review.