Lehman v. Nakshian

1981-06-26

Headline: Court blocks jury trials in age-discrimination suits against the federal government, leaving federal employee plaintiffs to bench trials and narrowing their trial options in ADEA cases.

Holding: The Court held that Congress did not clearly grant a right to trial by jury for age-discrimination lawsuits against the United States under §15(c) of the ADEA, so plaintiffs suing the federal government may not have jury trials.

Real World Impact:

Prevents jury trials in federal-government age-discrimination lawsuits.
Leaves factual disputes in such suits to judges instead of juries.
Reduces plaintiffs’ trial options when suing federal employers.

Topics: age discrimination, federal employment, jury trials, suing the federal government

Summary

Background

A 62-year-old civilian Navy employee sued the Secretary of the Navy under the Age Discrimination in Employment Act and asked for a jury trial. The District Court allowed the jury demand, and a divided Court of Appeals agreed. The dispute turns on §15(c) of the ADEA, which lets federal employees sue for “legal or equitable relief.” Congress had separately amended the ADEA in 1978 to add an explicit jury right for private-employer cases under §7(c).

Reasoning

The Court framed the issue as whether Congress clearly made a jury trial part of the United States’ consent to be sued. The majority emphasized that the Seventh Amendment does not automatically apply to suits against the Government and that waivers of sovereign immunity must be clear. Because Congress did not expressly provide a jury trial right in §15(c), and because §15 was patterned after Title VII (where jury trials are not available), the Court found no clear statutory grant. The Court also noted the legislative history lacks any mention of jury trials for federal ADEA claims and pointed to a 1978 change that made §15 self-contained. For these reasons the Supreme Court reversed the Court of Appeals.

Real world impact

Federal employees who sue the United States under §15(c) of the ADEA may not demand jury trials; judges will decide factual disputes in those cases. That changes how cases are tried, may affect settlement leverage, and shapes litigation strategy for age-discrimination claims against federal employers. The ruling addresses trial procedure, not the merits of discrimination claims.

Dissents or concurrances

The dissent argued Congress showed intent to allow juries by authorizing “legal or equitable relief” and by placing these cases in district courts, and it viewed Lorillard and legislative history as supporting a jury right.