## Facts

- Ellen Mendelsohn, age 51, was terminated by Sprint/United Management Company during a company-wide reduction in force.
- Mendelsohn brought an individual claim under the Age Discrimination in Employment Act (ADEA), alleging that her termination was based on age.
- At trial, Mendelsohn sought to introduce testimony from other former Sprint employees who claimed they also experienced age discrimination (“me-too” evidence).
- Sprint moved in limine to exclude the testimony, arguing it was irrelevant because the other employees had different supervisors and that it posed unfair prejudice and related harms under Federal Rule of Evidence 403.
- The district court excluded the testimony on the ground that discrimination against employees not “similarly situated” to Mendelsohn was inadmissible, and a jury returned a verdict for Sprint.
- The Tenth Circuit treated the district court’s ruling as adopting a categorical rule that evidence from employees of other supervisors is irrelevant, held the exclusion erroneous, and ordered a new trial.

## Issues

1. Whether “me-too” testimony from employees supervised by different managers is subject to a categorical admissibility or inadmissibility rule in an individual ADEA case.
2. Whether the court of appeals properly reviewed the district court’s evidentiary ruling, including whether it could substitute its own Rules 401 and 403 analysis.
3. What an appellate court should do when a district court’s evidentiary reasoning is unclear or ambiguous.

## Decision

- The Supreme Court unanimously vacated the Tenth Circuit’s judgment and remanded.
- The Court held the Tenth Circuit erred by assuming the district court applied a per se rule and then conducting its own relevance and prejudice analysis under Rules 401 and 403.
- The Court stated that the relevance and admissibility of “me-too” evidence in an individual ADEA case is fact-dependent and cannot be resolved by categorical rules.
- The Court instructed that when the basis for a district court’s evidentiary ruling is unclear, the proper course is to remand for clarification rather than replace the trial court’s judgment with the appellate court’s balancing.

## Legal Principles

- Evidentiary rulings under Rules 401, 402, and 403 are reviewed for abuse of discretion, reflecting deference to the trial court’s case familiarity and experience managing evidence.
- “Me-too” evidence is neither automatically admissible nor automatically inadmissible in individual employment-discrimination cases; relevance depends on context and connection to the plaintiff’s theory and proof.
- Appellate courts should not infer a categorical evidentiary rule from ambiguous trial-court language and then decide admissibility in the first instance.
- If the trial court’s reasoning is insufficiently explained to permit proper review, remand for clarification is appropriate.

## Conclusion

The Court required case-specific treatment of “me-too” testimony under the Federal Rules of Evidence and reaffirmed that appellate courts must review trial-court relevance and prejudice determinations deferentially, remanding when the trial court’s rationale is unclear rather than applying categorical rules or conducting independent balancing.


Sprint/United Mgmt. Co. v. Mendelsohn, 552 U.S. 379 (2008)