Employment & Labor Law
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General Dynamics Land Systems, Inc. v. Cline
17 Fla. L. Weekly Fed. S125a (U.S. February 24, 2004)
Present and former employees between ages of 40 and 49 sued under Age Discrimination in Employment Act (ADEA), alleging that collective bargaining agreement's elimination of employer's retiree health insurance benefits program for workers then under 50 impermissibly discriminated against younger workers. The United States District Court for the Northern District of Ohio granted employer's motion to dismiss, holding that the federal claim was one of reverse age discrimination, upon which no court had ever granted relief under the ADEA. The United States Court of Appeals for the Sixth Circuit reversed and remanded. The Sixth Circuit court held that Section 623(a)(1)'s prohibition of discrimination is so clear on its face that if Congress had meant to limit its coverage to protect only the older worker against the younger, it would have said so. Certiorari was granted. The United States Supreme Court reversed. It held that the more expansive reading of Section 623(a)(1) adopted by the circuit court does not square with the natural reading of the whole provision prohibiting discrimination. If Congress had been worrying about protecting the younger against the older, it would not likely have ignored everyone under 40. The court found that it owed no deference to the EEOC's contrary reading because Chevron deference is only called for when "the devices of judicial construction have been tried and found to yield no clear sense of congressional intent." Because the regular interpretation of the provision leaves no serious question, discrimination against the relatively young is outside ADEA's protection, and thus the employer did not violate ADEA's prohibition against discrimination "because of . . . age" by eliminating health insurance benefits program for workers under 50 but retaining the program for workers over 50.
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