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Mount Lemmon Fire District v. Guido

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Supreme Court of the United States
Mount Lemmon Fire District v. Guido
Term: 2018
Important Dates
Argument: October 1, 2018
Decided: November 6, 2018
Vote
8-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch


Mount Lemmon Fire District v. Guido is a case argued during the October 2018 term of the U.S. Supreme Court. Arguments in the case took place on October 1, 2018. The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. It was originally accepted to be heard during the October 2017 term but was deferred. The court affirmed the judgment of the Ninth Circuit and unanimously ruled that the Age Discrimination in Employment Act (ADEA) applies to all public employers, including those with fewer than 20 employees.[1]

HIGHLIGHTS
  • The case: Two employees of the Mount Lemmon Fire District in Arizona filed an age discrimination lawsuit against the Fire District. The Fire District argued that the Age Discrimination in Employment Act (ADEA) did not apply to the district because it employed fewer than 20 people. The plaintiffs argued that the 20-employee requirement in the ADEA did not apply to state political subdivisions. The district court granted summary judgment to the Fire District, ruling that the Fire District did not fall within the ADEA because it employed fewer than 20 people. On appeal, the Ninth Circuit reversed, ruling that the 20-employee minimum applied only to private employers.
  • The issue: Does the 20-employee minimum that the ADEA applies to private employers also apply to state political subdivisions?[2]
  • The outcome: The court ruled that the Age Discrimination in Employment Act (ADEA) applies to all public employers, including those with fewer than 20 employees.


    • You can review the lower court's opinion here.[3]

    Timeline

    The following timeline details key events in this case:

    • November 6, 2018: The U.S. Supreme Court ruled that the Age Discrimination in Employment Act (ADEA) applies to all public employers.
    • October 1, 2018: Oral argument
    • July 9, 2018: U.S. Supreme Court agreed to hear case
    • January 10, 2018: Petition filed with U.S. Supreme Court
    • June 19, 2017: The Ninth Circuit ruled that the 20-employee minimum applied only to employers "engaged in an industry affecting commerce" and that the minimum did not apply to the subsection that added state political subdivisions to the definition of employer under the ADEA.

    Background

    This case focused on the Age Discrimination in Employment Act (ADEA). The ADEA prohibited employers from discriminating against employees based on age. The issue in this case was whether the 20-employee minimum in § 630(b) applied only to employers "in an industry affecting commerce," or whether the minimum also applied to "a State or political subdivision of a State."

    The Ninth Circuit summarized the case background:

    “ John Guido and Dennis Rankin were both hired in 2000 by Mount Lemmon Fire District, a political subdivision of the State of Arizona. Guido and Rankin served as full-time firefighter Captains. They were the two oldest full-time employees at the Fire District when they were terminated on June 15, 2009, Guido at forty-six years of age and Rankin at fifty-four.


    Guido and Rankin subsequently filed charges of age discrimination against the Fire District with the Equal Employment Opportunity Commission ('EEOC'), which issued separate favorable rulings for each, finding reasonable cause to believe the Fire District violated the Age Discrimination in Employment Act, 29 U.S.C. §§ 621–34 ('ADEA'). They then filed this suit for age discrimination against the Fire District in April 2013.
    The district court granted the Fire District’s motion for summary judgment, concluding that it was not an 'employer' within the meaning of the ADEA.[3][4]

    		”

    Guido and Rankin then appealed to the Ninth Circuit. On appeal, the Ninth Circuit reversed the district court's ruling. The Ninth Circuit concluded that the 20-employee minimum applied only to employers "engaged in an industry affecting commerce" and that the minimum did not apply to the subsection that added state political subdivisions to the definition of employer under the ADEA.[3]

    The Fire District appealed to the United States Supreme Court, and the court agreed to hear the case on July 9, 2018.

    Question presented

    Question presented:

    "Under the ADEA, does the same twenty-employee minimum that applies to private employers also apply to political subdivisions of a State, as the Sixth, Seventh, Eighth, and Tenth Circuits have held, or does the ADEA apply instead to all State political subdivisions of any size, as the Ninth Circuit held in this case?"[2]

    Audio

    • Audio of oral argument:[5]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Ruth Bader Ginsburg delivered the opinion of the court. The court affirmed the judgment of the Ninth Circuit and unanimously ruled that the Age Discrimination in Employment Act (ADEA) applies to all public employers, including those with fewer than 20 employees.[1]

    Opinion

    In her opinion, Ginsburg described how the word "employer" evolved. She wrote that the Fair Labor Standards Act includes public employers of all sizes. She then discussed the court's decision to reject the Fire District’s interpretation of "also means" in the statute under question. According to SCOTUSblog, "The fire district’s reading, Ginsburg wrote, is inconsistent with both the court’s own precedent and Congress’ use of 'also means' in other statutory contexts. Moreover, the fire district’s reading would yield an odd result in that it would apply the 20-employee threshold to a 'state or political subdivision' but not to the immediately preceding clause, which covers 'any agent' of a person engaged in an industry affecting commerce."[1][6]

    Ginsburg concluded by rejecting the fire district’s argument that ADEA could harm public services. She wrote,

    “ The Fire District warns that applying the ADEA to small public entities risks curtailment of vital public services such as fire protection. Experience suggests otherwise. For 30 years, the Equal Employment Opportunity Commission has consistently interpreted the ADEA as we do today. EEOC Compliance Manual: Threshold Issues §2–III(B)(1)(a)(i), and n. 99. See also Kelly, 801 F. 2d, at 270, n. 1. And a majority of States forbid age discrimination by political subdivisions of any size; some 15 of these States subject private sector employers to age discrimination proscriptions only if they employ at least a threshold number of workers. See Brief for Respondents 28–29, and n. 6 (collecting citations). No untoward service shrinkages have been documented.


    In short, the text of the ADEA’s definitional provision, also its kinship to the FLSA and differences from Title VII, leave scant room for doubt that state and local governments are “employer[s]” covered by the ADEA regardless of their size.[4]

    		”

    Text of the opinion

    • Read the full opinion here.

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, "Mount Lemmon Fire District v. Guido" Opinion, November 6, 2018
    2. ↑ 2.0 2.1 Supreme Court of the United States, "Mount Lemmon Fire District v. Guido Question Presented," February 26, 2018
    3. ↑ 3.0 3.1 3.2 United States Court of Appeals for the 9th Circuit, "Mount Lemmon Fire District v. Guido Opinion," June 19, 2017
    4. ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, Mount Lemmon Fire District v. Guido, argued October 1, 2018
    6. ↑ SCOTUSblog, "Opinion analysis: Federal age-discrimination law applies to all public employees," November 6, 2018
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