Reeves v. Sanderson Plumbing Products, Inc.

Supreme Court of the United States · 2000 · Civil Procedure

530 U.S. 133 (2000)

Updated July 29, 2026

Civil ProcedureJudgment as a Matter of LawEmployment DiscriminationADEARule 50McDonnell Douglaspretextprima facie case

Facts

Roger Reeves, age 57, had worked for Sanderson Plumbing for 40 years and was discharged after an audit that the company claimed showed inaccurate attendance recordkeeping in the Hinge Room. At trial, the employer asserted that Reeves was fired for failing to maintain accurate records, while Reeves introduced evidence that his records were accurate or explainable, that some discipline decisions were Caldwell's responsibility, and that the company had not substantiated claimed overpayments or grievances. Reeves also introduced testimony that Powe Chesnut, who was described as wielding absolute power in the company, made age-based remarks to him and treated him more harshly than a younger supervisor. The jury found for Reeves and the Fifth Circuit nonetheless overturned the verdict.

Issue

When an ADEA plaintiff establishes a prima facie case and offers sufficient evidence for a factfinder to reject the employer's stated nondiscriminatory reason, is that evidence sufficient to permit a finding of intentional discrimination? Also, under the record in this case, was the employer entitled to judgment as a matter of law under Rule 50?

Rule

A plaintiff's prima facie case, combined with sufficient evidence to find that the employer's asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated. But such a showing will not always be enough; judgment as a matter of law may still be proper where the record conclusively reveals another nondiscriminatory reason, or where the plaintiff's showing of falsity is weak and there is abundant, uncontroverted independent evidence that no discrimination occurred. On a Rule 50 motion, the court must review the whole record, draw all reasonable inferences for the nonmovant, and may not make credibility determinations or weigh the evidence.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, 62-year-old warehouse supervisor Elena Morris sued Desert Span Fixtures under the ADEA after being fired and replaced by a 34-year-old. At trial, Elena made out a prima facie case and introduced evidence that the company's stated reason—chronic inventory errors—was false because the error reports had been altered after her discharge and multiple witnesses testified her counts were accurate.

After a jury returns a verdict for Elena, the employer renews its Rule 50 motion and argues that Elena also had to produce additional independent evidence of age bias beyond her prima facie case and proof of falsity. How should the court rule?

Explanation. The governing rule is that a plaintiff's prima facie case, combined with sufficient evidence for a rational factfinder to reject the employer's asserted reason, may permit a finding of intentional discrimination. The court may not require additional independent evidence in every case. Although the prima facie presumption drops out once the employer produces a reason, the underlying prima facie evidence may still be considered with the pretext evidence on the ultimate issue. (Derived from Reeves v. Sanderson Plumbing Products, Inc. (2000).)