## Facts

- James O’Connor worked for Consolidated Coin Caterers Corp. from 1978 until August 10, 1990.
- O’Connor was 56 years old when he was discharged.
- Consolidated replaced O’Connor with a 40-year-old worker.
- O’Connor sued under the Age Discrimination in Employment Act of 1967 (ADEA), alleging he was terminated because of age.
- The district court granted summary judgment to Consolidated after discovery.

## Issues

1. Whether an ADEA plaintiff asserting discriminatory discharge must show, as part of a McDonnell Douglas prima facie case, that he was replaced by someone outside the ADEA’s protected age group (under 40).

## Decision

- The Supreme Court unanimously reversed the Fourth Circuit and remanded.
- The Court held that an ADEA plaintiff need not show replacement by someone under 40 to establish a prima facie case under McDonnell Douglas.
- The relevant inference is whether the replacement is “substantially younger,” not whether the replacement falls outside the protected group.

## Legal Principles

- The ADEA prohibits discrimination “because of” an individual’s age; the statute’s 40-and-over coverage limit does not convert the claim into one about “class membership.”
- Prima facie elements under McDonnell Douglas must bear a logical connection to the type of discrimination alleged.
- In ADEA discharge cases, replacement by someone substantially younger is more probative of age discrimination than replacement by someone outside the protected age group.
- The McDonnell Douglas prima facie formulation is not rigid; its elements are a flexible method for assessing whether the evidence supports an inference of unlawful discrimination.

## Conclusion

An ADEA plaintiff can satisfy the replacement-related component of the McDonnell Douglas prima facie case without proving the replacement was under 40; the proper focus is whether the replacement was substantially younger, supporting an inference that the termination occurred because of age.


O’Connor v. Consolidated Coin Caterers Corp., 517 U.S. 308 (1996)