Reeves v. Sanderson Plumbing Prods. Inc.

530 U.S. 133 (2000)


Roger Reeves (P) was 57 years old and had spent 40 years in the employ of Sanderson Plumbing Products, Inc. (D), a manufacturer of toilet seats and covers. P's responsibilities included recording the attendance and hours of those under his supervision and reviewing a weekly report that listed the hours worked by each employee. Management was informed that 'production was down' in P’s area because employees were often absent and were 'coming in late and leaving early.' Monthly attendance reports did not indicate a problem. An audit was ordered and 'numerous timekeeping errors and misrepresentations on the part of Caldwell, Reeves, and Oswalt were discovered.' P and Caldwell were fired. P sued contending that he had been fired because of his age in violation of the Age Discrimination in Employment Act of 1967. D contended that it had fired P due to his failure to maintain accurate attendance records, while P attempted to demonstrate that D's explanation was pretext for age discrimination. The District Court twice denied oral motions by D for judgment as a matter of law under Rule 50 of the Federal Rules of Civil Procedure, and the case went to the jury. The court instructed the jury that 'if the plaintiff fails to prove age was a determinative or motivating factor in the decision to terminate him, then your verdict shall be for the defendant.' P got the verdict and $35,000 in compensatory damages, and found that D's age discrimination had been 'willful.' Judgment was entered for $70,000. D then renewed its motion for judgment as a matter of law and alternatively moved for a new trial. The District Court denied D’s motions and granted P's, awarding him $28,490.80 in front pay for two years' lost income. The Court of Appeals for the Fifth Circuit reversed, holding that petitioner had not introduced sufficient evidence to sustain the jury's finding of unlawful discrimination. The court acknowledged that petitioner 'very well may' have offered sufficient evidence for 'a reasonable jury [to] have found that [respondent's] explanation for its employment decision was pretextual.' But, that was 'not dispositive' of the ultimate issue--namely, 'whether Reeves presented sufficient evidence that his age motivated [respondent's] employment decision.' The court noted that age-based comments 'were not made in the direct context of Reeves's termination.'