{"id":11517461964,"title":"Course #337- Supreme Court: Meacham vs Knolls Atomic Power Laboratory - CD","handle":"course-337-supreme-court-meacham-vs-knolls-atomic-power-laboratory-cd","description":"\u003cp\u003e\u003cstrong\u003eCourse 337\u003c\/strong\u003e\u003c\/p\u003e\n\u003cp\u003e\u003cstrong\u003e1 hour MCLE Credit\u003c\/strong\u003e\u003c\/p\u003e\n\u003cmeta charset=\"utf-8\"\u003e\n\u003cp\u003eWhen the New York-based federal research laboratory Knolls Atomic Power Lab instituted a downsizing program, it asked supervisors to rank employees based on three factors: performance, flexibility, and the criticality of their skills, and then to add points for years of service in order to determine who would be dismissed. Of the thirty-one employees who were let go, all but one were over the age of forty. Twenty-six of these dismissed employees filed suit against Knolls for age discrimination in violation of the Age Discrimination in Employment Act (ADEA). A jury found for the employees and the U.S. Court of Appeals for the Second Circuit affirmed.\u003c\/p\u003e\n\u003cp\u003eHowever the U.S. Supreme Court vacated the judgment, relying on its 2005 decision in\u003cspan\u003e \u003c\/span\u003e\u003cem\u003eSmith v. City of Jackson\u003c\/em\u003e\u003cspan\u003e \u003c\/span\u003eto hold that \"an employer is not liable under the ADEA so long as the challenged employment action, in relying on specific non-age factors, constitutes a reasonable means to the employer's legitimate goals.\" On remand, the Second Circuit vacated its previous decision and held that the employees had failed to carry their burden of proving the evaluation system unreasonable. In seeking Supreme Court review, the employees argued that it should be Knolls, not them, who must prove the reasonableness of an action that would otherwise be prohibited.\u003c\/p\u003e\n\u003cp\u003eQuestion:\u003c\/p\u003e\n\u003cmeta charset=\"utf-8\"\u003e\n\u003cp\u003e\u003cspan\u003eUnder the Supreme Court's decision in \u003c\/span\u003e\u003cem\u003eSmith v. City of Jackson\u003c\/em\u003e\u003cspan\u003e, must the employer or the employee prove the reasonableness of adverse employment decisions occurring as part of a claim for age discrimination under the federal Age Discrimination in Employment Act?\u003c\/span\u003e\u003c\/p\u003e\n\u003cp\u003e\u003cspan\u003eObjectives:\u003c\/span\u003e\u003c\/p\u003e\n\u003cul\u003e\n\u003cli\u003eAnalyze the case and its conclusion and decision. How was the question above answered? 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Of the thirty-one employees who were let go, all but one were over the age of forty. Twenty-six of these dismissed employees filed suit against Knolls for age discrimination in violation of the Age Discrimination in Employment Act (ADEA). A jury found for the employees and the U.S. Court of Appeals for the Second Circuit affirmed.\u003c\/p\u003e\n\u003cp\u003eHowever the U.S. Supreme Court vacated the judgment, relying on its 2005 decision in\u003cspan\u003e \u003c\/span\u003e\u003cem\u003eSmith v. City of Jackson\u003c\/em\u003e\u003cspan\u003e \u003c\/span\u003eto hold that \"an employer is not liable under the ADEA so long as the challenged employment action, in relying on specific non-age factors, constitutes a reasonable means to the employer's legitimate goals.\" On remand, the Second Circuit vacated its previous decision and held that the employees had failed to carry their burden of proving the evaluation system unreasonable. In seeking Supreme Court review, the employees argued that it should be Knolls, not them, who must prove the reasonableness of an action that would otherwise be prohibited.\u003c\/p\u003e\n\u003cp\u003eQuestion:\u003c\/p\u003e\n\u003cmeta charset=\"utf-8\"\u003e\n\u003cp\u003e\u003cspan\u003eUnder the Supreme Court's decision in \u003c\/span\u003e\u003cem\u003eSmith v. City of Jackson\u003c\/em\u003e\u003cspan\u003e, must the employer or the employee prove the reasonableness of adverse employment decisions occurring as part of a claim for age discrimination under the federal Age Discrimination in Employment Act?\u003c\/span\u003e\u003c\/p\u003e\n\u003cp\u003e\u003cspan\u003eObjectives:\u003c\/span\u003e\u003c\/p\u003e\n\u003cul\u003e\n\u003cli\u003eAnalyze the case and its conclusion and decision. How was the question above answered? Do you agree or disagree with this answer?\u003c\/li\u003e\n\u003c\/ul\u003e"}

Course #337- Supreme Court: Meacham vs Knolls Atomic Power Laboratory - CD

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Course 337

1 hour MCLE Credit

When the New York-based federal research laboratory Knolls Atomic Power Lab instituted a downsizing program, it asked supervisors to rank employees based on three factors: performance, flexibility, and the criticality of their skills, and then to add points for years of service in order to determine who would be dismissed. Of the thirty-one employees who were let go, all but one were over the age of forty. Twenty-six of these dismissed employees filed suit against Knolls for age discrimination in violation of the Age Discrimination in Employment Act (ADEA). A jury found for the employees and the U.S. Court of Appeals for the Second Circuit affirmed.

However the U.S. Supreme Court vacated the judgment, relying on its 2005 decision in Smith v. City of Jackson to hold that "an employer is not liable under the ADEA so long as the challenged employment action, in relying on specific non-age factors, constitutes a reasonable means to the employer's legitimate goals." On remand, the Second Circuit vacated its previous decision and held that the employees had failed to carry their burden of proving the evaluation system unreasonable. In seeking Supreme Court review, the employees argued that it should be Knolls, not them, who must prove the reasonableness of an action that would otherwise be prohibited.

Question:

Under the Supreme Court's decision in Smith v. City of Jackson, must the employer or the employee prove the reasonableness of adverse employment decisions occurring as part of a claim for age discrimination under the federal Age Discrimination in Employment Act?

Objectives:

  • Analyze the case and its conclusion and decision. How was the question above answered? Do you agree or disagree with this answer?

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