General Dynamics Land Systems, Inc. v. Cline 540 U.S. 581 (2004)
General Dynamics entered an
agreement with a union that eliminated their obligation to pay health
benefits to retirees. But employees who were 50 and older were
Cline was an employee who was
not yet 50, but who was over 40. That meant that he was covered by the Age
Discrimination in Employment Act (ADEA) (29 U.S.C. §623). He sued, claiming that his loss of benefits
was a form of age-discrimination.
He only lost the benefits
because he was too young to be
ADA §623(1)(1) covers "discrimination because of an
The term age is left undefined.
The Trial Court found for
General Dynamics. Cline appealed.
The Trial Court found that
no court had ever granted relief under ADEA for reverse age discrimination.
The Appellate Court reversed.
General Dynamics appealed.
The Appellate Court looked
to the plain language and found
that the prohibition of discrimination was so clear that if Congress had
meant to limit its coverage to protect only older workers it would have
The Appellate Court also
noted that the Equal Employment Opportunity Commission (EEOC) interpreted
the Statute to cover reverse age discrimination.
The US Supreme Court reversed.
The US Supreme Court found
that the text, structure, purpose and history of ADEA along with its relationship to other Federal
Statutes, show that ADEA
is not meant to stop an employer from favoring an older employee over a
The Court noted that the
term 'age' is ambiguous and a broad interpretation would include reverse
age discrimination. However, that interpretation does not "square
with the natural reading of the whole provision."
The Court noted that the
term 'age' does not have to have the same meaning every time it is used
in the ADEA.
The Court noted that
Statutory language must be read in context to determine meaning.
The Court found that there
was only one statement from one Senator in the legislative history shows that Congress intended the ADEA
to stop reverse age discrimination. That's not enough to be convincing.
There is little evidence
that reverse age discrimination is a problem.
The Court noted that if
Congress had meant it to cover younger workers, they would have written
language to include those under 40.
The Court found that the
Court is not required to give deference to the EEOC because the EEOC is
The Court looked to Chevron
U.S.A. Inc. v. Natural Resources Defense Council (467 U.S. 837 (1984)), which said that if a
Statute is ambiguous, the courts must give deference to an Agency
interpretation as long as that interpretation is reasonable and
In this case, the Court
found that there was no ambiguity in the Statute, and gave no room for
the EEOC to interpret the Congressional intent. Therefore their
interpretation was not reasonable.
In a dissent, it was argued
There was room for
interpretation of the ADEA and it
was reasonable for the EEOC to have made the interpretation they made.
"Because §623(a)(1) does not unambiguously require a different
interpretation...the EEOC's regulation is an entirely reasonable
interpretation of the text."
The plain language of the Statute means that younger workers can
If a company fired a worker
for being too young, what else would you call it except "age
The Court had already
interpreted sexual harassment Statutes to cover situations where men are
being harassed, isn't this ruling inconsistent?
Steps in Interpreting Agency
Statutes, based on the Chevron Doctrine: