Gen. Dynamics Land Systems v. Cline
Citation and Court
540 U.S. 581 (2004), Supreme Court of the United States
Facts
General Dynamics entered into a collective bargaining agreement that eliminated health benefits for subsequently retired workers under the age of fifty while preserving benefits for those fifty and older. Workers between the ages of forty and forty-nine — who were within the ADEA’s protected class of workers forty and over — sued, arguing that the age-based distinction discriminated against younger members of the protected class in favor of older workers, in violation of the Age Discrimination in Employment Act.
Issue
Whether the ADEA prohibits an employer from favoring older workers over younger workers within the protected class (workers age forty and over), i.e., whether the ADEA bars reverse age discrimination.
Holding
The Supreme Court held 6–3 that the ADEA does not prohibit employers from favoring older workers over younger workers within the protected class; the Act was intended to protect older workers from discrimination in favor of youth, not to bar all age-based distinctions among those over forty.
Rule / Doctrine
Statutory text must be read in light of the statute’s evident purpose and the ordinary meaning of its words. The ADEA’s prohibition on discrimination “because of age” was enacted to protect older workers from being disadvantaged relative to younger workers, not to prevent employers from preferring older workers. Favoring older members of the protected class over younger members does not constitute prohibited age discrimination under the ADEA.
Significance
Gen. Dynamics v. Cline is a significant case on statutory interpretation, illustrating that courts may look to a statute’s purpose and legislative history to resolve textual ambiguity, and that “discrimination because of age” is not symmetrical — the statute protects older workers against younger competition, not the reverse.