530 U.S. 133 (2000)
Roger Reeves worked for Sanderson Plumbing Products, Inc. for forty years until his discharge in October 1995 at the age of fifty-seven.1
He supervised the regular line in the Hinge Room, where Joe Oswalt supervised the special line and Russell Caldwell managed the department.
Reeves's duties included recording employee attendance and hours and reviewing weekly attendance reports.2
In the summer of 1995, after being told that production was down due to employee absences and tardiness, manufacturing director Powe Chesnut ordered an audit of the Hinge Room timesheets for July, August, and September.
The audit uncovered numerous timekeeping errors and misrepresentations by Caldwell, Reeves, and Oswalt.3
Chesnut, along with vice presidents Dana Jester and Tom Whitaker, recommended to company president Sandra Sanderson that Reeves and Caldwell be fired, and Sanderson discharged both in October 1995.
Reeves filed suit in June 1996 in the United States District Court for the Northern District of Mississippi, alleging that his termination violated the Age Discrimination in Employment Act.4
At trial, Sanderson contended that Reeves was fired for failing to maintain accurate attendance records, while Reeves introduced evidence that his records were accurate and that Chesnut had shown age-based animus toward him.
The jury found in Reeves's favor, awarding thirty-five thousand dollars in compensatory damages and determining that the discrimination was willful, resulting in a seventy-thousand-dollar judgment plus an award of front pay.
The Court of Appeals for the Fifth Circuit reversed the judgment, concluding that Reeves had not presented sufficient evidence that his age motivated the employment decision even though he may have shown the company's explanation was pretextual.
The court considered factors such as the context of Chesnut's comments, the ages of other decisionmakers, and the fact that multiple supervisors were accused of recordkeeping issues.5
The Supreme Court granted certiorari to address the evidentiary requirements in such discrimination cases.6
Whether a defendant is entitled to judgment as a matter of law when the plaintiff's case consists exclusively of a prima facie case of discrimination and sufficient evidence for the trier of fact to disbelieve the defendant's legitimate, nondiscriminatory explanation for its action?7
A plaintiff's prima facie case of discrimination combined with sufficient evidence for a reasonable factfinder to reject the employer's nondiscriminatory explanation for its decision may permit the trier of fact to conclude that the employer unlawfully discriminated.8
No. Reeves established a prima facie case by demonstrating he was a member of the protected class at age fifty-seven.9 He was qualified for the Hinge Room supervisor position.10 He was discharged.11 He was replaced by three individuals in their thirties.12
Reeves made a substantial showing that Sanderson Plumbing's explanation was false.13 The time clock often malfunctioned.14 He and Oswalt visually verified employee presence at the start of shifts.15 Disciplinary writeups were Caldwell's responsibility rather than his own.16
This evidence permitted the jury to infer intentional discrimination from the falsity of the employer's explanation.17
A defendant is not entitled to judgment as a matter of law when the plaintiff's evidence consists of a prima facie case and sufficient evidence of pretext.18
Related opinions on this issue
Justice Ginsburg concurred to note that an employment discrimination plaintiff may survive judgment as a matter of law by submitting evidence establishing a prima facie case.19 She noted that evidence from which a rational factfinder could conclude that the employer's proffered explanation was false also suffices.20 She observed that it may be incumbent on the Court in an appropriate case to define more precisely the circumstances in which plaintiffs will be required to submit evidence beyond these two categories.21
She anticipated such circumstances will be uncommon.22 A party's dishonesty about a material fact gives rise to a rational inference of culpability unless conclusively demonstrated otherwise by evidence the district court is required to credit.23
Whether the employer was entitled to judgment as a matter of law under the particular circumstances presented here?24
Under Rule 50 a court should render judgment as a matter of law when a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue.25 The court reviews all evidence while drawing reasonable inferences in favor of the nonmovant without making credibility determinations.26
No. In addition to the prima facie case and evidence of pretext, Reeves introduced evidence that Chesnut was motivated by age-based animus.27 Chesnut commented that Reeves was so old he must have come over on the Mayflower.28 Chesnut also said Reeves was too damn old to do his job.29 Chesnut exercised absolute power within the company.30
Chesnut was married to the formal decisionmaker Sanderson.31 The Court of Appeals misapplied the Rule 50 standard by disregarding evidence favorable to Reeves.32 It failed to draw all reasonable inferences in his favor.33
The employer was not entitled to judgment as a matter of law under the particular circumstances presented here.34