Federal Court Rejects Age Discrimination Claim of Employee Terminated Pursuant to Company RIF

In Schoomaker v. Spartan Graphics Leasing, LLC, a federal appeals court upheld summary judgment of an employee's age discrimination claim. The employee was terminated pursuant to a RIF and claimed that she was chosen over other younger employees to be terminated because of her age. Recognizing that in the RIF context a plaintiff is required to present proof that age played a role in the decision to select her over other employees, the Court held that the plaintiff failed to meet that burden. At most, the Court concluded that the plaintiff had shown nothing more than the mere "fact of an age differential," which was not enough to get her case to a jury. A copy of the decision can be read here.

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