Supreme Court Reverses Age Discrimination Ruling on Procedural Grounds
The high court ruled in Sprint/United Management Company v. Mendelsohn, No. 06-1221 (Feb. 26, 2008) that the 10 th U.S. Circuit Court of Appeals was wrong to overrule a trial court judge. U.S. District Judge Kathryn H. Vratil for the U.S. District Court for the District of Kansas excluded testimony Ellen Mendelsohn wanted to present to prove her claims that she was included in the Sprint/United Management Company’s personnel reductions because of her age; she was 51 when she was fired.
In throwing out Vratil’s order, the 10 th Circuit ruled in November 2006 that e mployees trying to prove discrimination in a companywide reduction in force (RIF) do not have to limit themselves to co-workers with the same supervisor when presenting witnesses (See Sprint Employee Prevails in Appellate Court ADEA Ruling).
The appellate court held that the lower court had improperly applied the “same supervisor” rule set forth in a 1997 case to justify Vratil’s holding that Mendelsohn could only present testimony from co-workers assigned to the same boss as she was.
In an opinion written by Justice Clarence Thomas for the court, the Supreme Court ruled that the proper move would have been for the 10 th Circuit to send the case back to Vratil. Justices said the 10 th circuit should have ordered Vratil to clarify exactly why she excluded the testimony from five other Sprint employees over 40 who were also fired in the staffing reduction and who were alleging discrimination but who had different supervisors than Mendelsohn.
“When a district court’s language is ambiguous, as it was here, it is improper for the court of appeals to presume that the lower court reached an incorrect legal conclusion,” Thomas wrote. “A remand directing the district court to clarify its order is generally permissible and would have been the better approach in this case.”
The Supreme Court noted that judgments about the relevance of certain evidence are more appropriately determined in the context of the facts and arguments in a particular case.
“Questions of relevance and prejudice are for the District Court to determine in the first instance,” Thomas wrote. “Rather than assess the relevance of the evidence itself and conduct its own balancing of its probative value and potential prejudicial effect, the Court of Appeals should have allowed the District Court to make these determinations in the first instance, explicitly and on the record. With respect to evidentiary questions in general and Rule 403 in particular, a district court virtually always is in the better position to assess the admissibility of the evidence in the context of the particular case before it.”
Mendelsohn was a manager in Sprint/United Management Company’s Overland Park, Kansas, business development and support group operations, when she was terminated as part of a companywide reduction in force affecting nearly 15,000 employees during an 18-month period. Mendelsohn sued Sprint for violation of the Age Discrimination in Employment Act.
The 10th Circuit’s Mendelsohn ruling is here . The Supreme Court’s decision is here .