## Facts

- Ameritech Services, Inc. and Indiana Bell Telephone Co. implemented a major early-1990s corporate restructuring that substantially reduced middle-management positions through a reduction in force (RIF).
- Groups of former management-level employees (generally older and long-tenured) challenged terminations and related employment actions arising from the RIF.
- Plaintiffs asserted claims under the Age Discrimination in Employment Act (ADEA) and ERISA (including interference with benefits theories), and a subset of plaintiffs alleged constructive demotion based on reduced duties, status, or pay.
- Plaintiffs contended the RIF process and evaluation criteria favored younger employees, relied in part on statistical disparities, and pointed to certain management remarks as evidence of age-based motives and benefit-cost avoidance.
- Defendants maintained the actions were driven by competitive and economic pressures and were executed using performance-based and business-need criteria.
- The district court granted summary judgment to defendants on key ADEA and ERISA theories; the consolidated appeals followed, with the Seventh Circuit reviewing summary judgment de novo.

## Issues

1. Whether plaintiffs produced sufficient evidence (direct, circumstantial, or statistical) to create a triable issue that age was the determinative reason for adverse employment actions in the RIF under the ADEA.
2. Whether plaintiffs produced sufficient evidence that defendants acted with specific intent to interfere with attainment of ERISA-protected benefits, in violation of ERISA § 510 and related enforcement provisions.
3. Whether the subset of plaintiffs alleging constructive demotion showed an objectively significant adverse change amounting to a constructive demotion under governing standards.

## Decision

- The Seventh Circuit largely affirmed the district court’s rulings for defendants.
- The court affirmed summary judgment on the ADEA claims, holding plaintiffs’ proof did not permit a reasonable inference that age, rather than legitimate restructuring criteria, caused the challenged decisions.
- The court affirmed rejection of ERISA interference claims, holding the evidence did not show a specific intent to prevent plaintiffs from attaining pension or other benefit rights.
- The court rejected the constructive demotion theories as failing to meet the standard for a constructive adverse employment action in the context of a broad reorganization.

## Legal Principles

- In an ADEA RIF case, plaintiffs must present evidence that age actually motivated the employer’s decision; disproportionate impact on older employees, without more, is insufficient.
- Statistical proof must be methodologically sound and probative of decision-making within relevant selection units; weak or poorly matched statistics do not create a genuine issue for trial.
- Alleged age-related remarks do not establish discrimination unless tied to the relevant decision-makers and the specific employment decisions at issue.
- To prove ERISA § 510 interference, a plaintiff must show the employer acted with specific intent to interfere with attainment of benefits; incidental benefit reductions resulting from general cost cutting do not establish liability.
- Constructive demotion requires an objectively significant adverse change; ordinary consequences of reorganization, without stronger proof of targeted discriminatory treatment or intolerable conditions, are not enough.

## Conclusion

The Seventh Circuit upheld summary judgment for the employer because the plaintiffs’ evidence did not support a reasonable finding that the RIF decisions were driven by age discrimination or by a specific intent to interfere with ERISA-protected benefits, and the alleged demotions did not meet the threshold for constructive adverse action.


Adams v. Ameritech Servs., Inc., 231 F.3d 414 (7th Cir. 2000)