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 grandfathered in.
  • 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 grandfathered in.
    • ADA 623(1)(1) covers "discrimination because of an individual's age."
      • 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 said so.
    • 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 younger one.
    • 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 "clearly wrong."
      • 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 permissible.
        • 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 that:
    • 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 sue.
      • If a company fired a worker for being too young, what else would you call it except "age discrimination?"
    • 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: