Procedural History: A) Lickteig filed a charge with EEOC that he was not granted benefits because of his age.
B) EEOC failed to resolve this case (Kentucky Retirement Systems v. EEOC).
C) The EEOC sued Kentucky Retirement Systems (KRS) for developing a discriminatory retirement benefit plan.
D) The Court presented summary judgment to petitioners.
E) The Court pointed to the lack of evidence presented by EEOC (defendant won).
Issue: A) Whether the new disability retirement plan for employees is based on discrimination.
B) Whether the fact the older employees are denied disability benefits compared to younger ones proves age-related discrimination.
Holding: A) The new retirement benefit plan does not violate ADEA (Age Discrimination in Employment Act).
B) EEOC’s arguments lack logic.
C) EEOC failed to present any facts to prove that the newly developed benefit plan is based on age discrimination because the concepts of pension status and age are distinct terms, and this distinction was taken into consideration when designing the benefit plan.
Rules: A) Discriminatory intent is commonly facially expressed, which means that malevolent motives are always present.
B) Using the probable cause standards, an action discriminatory on its face is the following:
According to ADEA,
In pension plan, age is the major factor
To treat an employee differently
Reasoning: A) Court relies on ADEA to deliver a holding.
According to ADEA, age-related discrimination is that based on the stereotyped perception of younger and older employees’ capacities. The newly developed retirement benefit plan uses the concept of age expressly, which means that older employees could as well be benefited.
B) Court uses pure logic to interpret case facts.
Using the probable cause standards (nature of employment and employees’ age), the Court concludes that the probable cause does not exist because, according to the KRS plan, older workers are usually put in advantage.
Facts: A) Age and pension status are two distinct concepts.
B) The formula for calculating benefits status considers age expressly.
C) Non-age-related rationale is clear in the new disability rules.
D) Stereotypical perception of capacity of younger and older workers is avoided in the KRS plan.
Words to Define:
Action discriminatory in its face