On June 21, 2023, the Massachusetts Supreme Judicial Court held that a former employee of Schneider Electric would get his day in court on his claim of age discrimination. The case, Adams v. Schneider Electric, involved an employee who was laid off in 2017. Adams alleged that he was laid off because of his age, and that Schneider Electric had violated the Massachusetts anti-discrimination laws.
Schneider Electric argued that Adams’ claims should be dismissed because he did not have sufficient evidence that he was laid off because of their age. The company argued that the workers’ terminations were simply part of a larger restructuring effort, and that there was no evidence that age was a factor in the decision-making process.
The trial court had granted the company’s motion for summary judgment and dismissed the case. The Appeals Court reversed that decision, and the Supreme Judicial Court affirmed the reversal, allowing the case to proceed to trial. The SJC found that the plaintiff had presented enough circumstantial evidence to create a reasonable inference that he was laid off because of his age. This evidence included internal company communications discussing a desire to encourage a more youthful workforce, or as they called it, “age diversity.” Even though there was no evidence that the person who decided to lay off the plaintiff was biased, the SJC held that the bias shown by other company officials could have tainted the determination.
The court’s decision is a significant victory for age discrimination plaintiffs in Massachusetts. It reinforces that plaintiffs do not need direct evidence of age discrimination to prevail in a lawsuit. Indeed, such “smoking gun” evidence is often lacking. Rather, plaintiffs can rely on circumstantial evidence to create a reasonable inference that they were discriminated against. In age discrimination claims, this decision clarifies that an employer’s desire to achieve a more youthful or younger workforce provides evidence of an impermissible bias against older workers. Even if the ultimate decision-maker is not biased, evidence of bias among upper management can be enough to sustain a claim.
The decision is also a reminder to employers that they must examine their motivations for changing workforce composition and be careful not to discriminate against older workers. Employers who lay off older workers should be able to show that the layoffs were justified by legitimate business reasons, and a desire to make the workforce younger may be viewed as discriminatory. If employers cannot show that the layoffs were justified, they may be liable for age discrimination.
Here at Bennett & Belfort, we frequently work with clients in age discrimination matters to counsel them and, if necessary, represent them in litigation. Please contact us if you would like to schedule a consultation.
Click here to read the court decision.