Meacham v. Knolls Atomic Power Laboratory
The Court ruled that when a company defends an age-discrimination lawsuit by arguing its layoff criteria were reasonable factors other than age, the company itself must prove that reasonableness — not just raise the argument and shift the burden back to the workers.
The decision resolves a split among appeals courts over who bears this burden, giving employees a clearer path to hold employers accountable when layoff scoring systems disproportionately affect older workers.
“That longstanding convention is part of the backdrop against which the Congress writes laws, and we respect it unless we have compelling reasons to think that Congress meant to put the burden of persuasion on the other side.”
Explaining why the employer, not the worker, must prove its non-age reasons were reasonable.
How it got here: A jury sided with the workers; the appeals court reversed on remand after this Court sent the case back in light of an intervening ruling, prompting the workers to seek review again.
The Case in Depth
What happened
A federal nuclear-weapons contractor, Knolls, was ordered to shrink its workforce after the Cold War ended. Managers scored employees on performance, flexibility, and critical skills, and the lowest scorers were laid off. Of 31 people let go, 30 were 40 or older. Many of them sued under the federal age-discrimination law, claiming the scoring process disproportionately hurt older workers even without deliberate intent.
The question before the Court
When older workers sue an employer for age discrimination based on the effect of a layoff plan, who has to prove the company's reasons were reasonable — the workers or the company?
The Court's answer
The employer, not the employee. The Court held that when a company defends an age-discrimination claim by arguing its criteria were based on "reasonable factors other than age," it must both raise that defense and convince the jury it's actually true — the full burden of persuasion, not just of production.
The Court reasoned that this defense is written the same way as another well-established affirmative defense in the same statute, and that longstanding legal convention puts the burden of proving an exception on whoever claims its benefit. It also ruled that a separate "business necessity" test doesn't apply alongside this defense, since applying both would create a confusing and redundant structure of proof that Congress never intended.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Older workers challenging layoffs or hiring criteria that hit them harder than younger colleagues will have an easier time in court, because companies — not the workers — must now prove their nondiscriminatory reasons are actually reasonable. Employers face a higher bar and higher litigation costs when defending workforce decisions with age-skewed effects.
What changes now
The case returns to the Second Circuit, which must decide whether Knolls actually proved its layoff-scoring criteria were reasonable, now that the correct legal standard places that burden on the company rather than on the workers. This is a final ruling on the legal question of who bears the burden, though the ultimate outcome of the lawsuit remains undecided pending further proceedings below.
What this does not decide
The Court did not decide whether Knolls's actual layoff criteria were reasonable — that question goes back to the lower court. It also expressly declined to review whether giving managers broad discretion in scoring layoffs itself counts as a reasonable factor other than age.
Concurrences and dissents
Concurrence — Justice Scalia
Justice Scalia agreed with the outcome but would have reached it by deferring to the EEOC's own reasonable interpretations of the statute, rather than the Court independently deciding both that the defense is an affirmative defense and that the business-necessity test doesn't apply. He viewed these as questions Congress left to the agency's judgment.
Dissent in part — Justice Thomas
Justice Thomas joined only the parts of the opinion holding that the reasonable-factors defense is an affirmative defense in disparate-treatment cases, because he continues to believe disparate-impact claims aren't even valid under this statute. He disagreed that the defense is principally relevant in disparate-impact cases, and would have affirmed for Knolls since only disparate-impact claims were at issue.
How the Court got there
The legal reasoning, step by step
- The Court read the age-discrimination law's text, which lists a 'reasonable factors other than age' exemption right alongside a separate exemption for job qualifications tied to age (like requiring young pilots) that courts have long treated as an affirmative defense — meaning the party raising it must prove it.
- Applying the traditional legal principle that whoever claims an exception to a general rule must prove that exception applies, the Court found nothing in the statute's text suggesting Congress meant this particular defense to work differently from its neighbor.
- The Court rejected the employer's argument that the 'reasonable factors other than age' language was simply part of what a worker must disprove to win, explaining that a prior decision, Smith v. City of Jackson, had already made clear that some non-age reason for a decision is assumed to exist in these disparate-impact cases — the real fight is over whether that reason was reasonable.
- The Court also rejected pairing this reasonableness defense with a separate 'business necessity' test borrowed from race-discrimination law, reasoning that using both tests together would create a confusing, overlapping structure of proof that Congress never intended.
- Because the employer bears the burden of proving its factor was reasonable, and the lower court had instead required the workers to prove it was unreasonable, the Court concluded the case needed to be reconsidered under the correct standard.
Doctrinal impact
Cases affected by this decision
Reaffirms Smith v. City of Jackson (544 U. S. 228)
The Court relied on this earlier ruling to explain how the reasonable-factors defense operates in disparate-impact claims.