## Facts

- Roger Reeves, age 57, worked for Sanderson Plumbing Products for about 40 years and supervised a production line in the “Hinge Room.”
- Reeves’s duties included recording employee attendance and hours and reviewing weekly reports; another supervisor, Joe Oswalt (mid-30s), supervised a different line under the same manager.
- In 1995, management asserted production was down due to attendance problems and ordered an audit of time sheets for July–September 1995.
- The company claimed the audit showed timekeeping errors and misrepresentations by Reeves, his manager Russell Caldwell (age 45), and Oswalt.
- After a recommendation by manufacturing director Powe Chesnut and others, the company president terminated Reeves and Caldwell in October 1995 but did not terminate Oswalt.
- Reeves sued under the Age Discrimination in Employment Act (ADEA), contending he was fired because of age; the company asserted it fired him for inaccurate attendance records.
- At trial, Reeves offered evidence that he accurately kept records and that Chesnut made age-related remarks suggesting bias.

## Issues

1. In an ADEA case, whether a plaintiff’s prima facie showing combined with evidence permitting a reasonable factfinder to reject the employer’s stated reason can support a finding of intentional discrimination.
2. Whether the employer was entitled to judgment as a matter of law after a jury verdict for the plaintiff where the plaintiff’s proof centered on prima facie evidence and pretext.

## Decision

- The Supreme Court unanimously reversed the Fifth Circuit.
- The Court held that a prima facie case, combined with sufficient evidence to disbelieve the employer’s explanation, may be adequate for a jury to find intentional discrimination under the ADEA.
- The Court held the Fifth Circuit erred by effectively requiring additional, independent proof of discriminatory intent and by reweighing evidence rather than applying the Rule 50 standard.
- Applying the proper standard, the Court concluded the evidence permitted a reasonable jury to find the company’s explanation false and age discrimination the actual motive; the employer was not entitled to judgment as a matter of law.
- The case was remanded for further proceedings consistent with the Court’s opinion, reinstating the jury verdict in practical effect.

## Legal Principles

- Under the McDonnell Douglas framework, once the employer articulates a legitimate, nondiscriminatory reason, the plaintiff may prevail by showing the reason is not worthy of credence; the burden of persuasion remains on the plaintiff throughout.
- A factfinder may (but need not) infer intentional discrimination from the falsity of the employer’s explanation together with the prima facie case; there is no categorical requirement of direct evidence or extra proof beyond pretext.
- In reviewing a Rule 50 motion, courts must consider the entire record, draw all reasonable inferences for the nonmovant, and may not make credibility determinations or weigh competing evidence.
- Evidence of pretext can be strengthened by proof bearing on who influenced the decision and by comparative treatment of employees implicated in the same asserted misconduct.

## Conclusion

The Court held that when an ADEA plaintiff presents a prima facie case and evidence from which a reasonable jury could find the employer’s stated reason false, the jury may infer intentional age discrimination; appellate courts may not overturn such a verdict by reweighing evidence on judgment as a matter of law.


Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000)