Article: RIGHT WITHOUT A REMEDY?: SUPREME COURT ALLOWS DISPARATE IMPACT CLAIMS UNDER THE ADEA

In Smith v. City of Jackson,1 decided in March, 2005, the Supreme Court held 5-3 that disparate impact claims may proceed under the Age Discrimination in Employment Act of 1967 (ADEA), which protects employees and job applicants aged 40 and over from age-based discrimination.2 Whereas disparate treatment claims assert that an employer intentionally discriminated against an individual because of his age, disparate impact claims allege that a facially neutral policy is illegal because it has a harsher impact on older workers. Under this theory, proof of intent to discriminate is not needed.3

Advocates of heightened legal protection for over-40 workers heartily cheered the announcement of ...

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