Sixth Circuit Court of Appeals Applies Heightened Standard of Proof to Age Discrimination Claims Arising as Part of Reductions in Force


The United States Court of Appeals for the Sixth Circuit recently affirmed a lower court decision rejecting an employee's age discrimination claim arising out of a reduction in force ("RIF"). In Geiger v. Tower Automotive, No. 08-1314, 2009 WL 2836538 (6th Cir. September 4, 2009), a 62-year old former employee of Tower Automotive ("Tower") brought claims of age discrimination under the federal Age Discrimination in Employment Act ("ADEA") and a Michigan state civil rights statute. In upholding the lower court decision, the Sixth Circuit reaffirmed its approach to analyzing age discrimination claims based on circumstantial evidence, including the application of a heightened standard of proof when such claims arise out of reductions in force.

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Published In: Civil Procedure Updates, Civil Rights Updates, Labor & Employment Updates

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