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cases/29usc623/f3d-900-923-obrien-v-caterpillar.case

Source: cases/29usc623/f3d-900-923-obrien-v-caterpillar.case

Case source: https://www.neochart.com/catalog/cases/f3d/volume_900/0923_01/index.html

Verbatim annotated passages

Here the plaintiffs have specifically identified a cause for the disparate impact: Caterpillar's decision to condition benefits on retirement eligibility, a status strongly correlated with age. No more is required.
In light of the substantial statistical disparities between the ages of retirement-eligible and nonretirement-eligible employees, the plaintiffs have established a prima facie disparate-impact case.
Caterpillar has satisfied its burden. The liquidation plan was justified by a reasonable factor other than age-several, actually.

Exact source text

casedsl 1

case /f3d/900/0923-01
  name O'Brien v. Caterpillar Inc.
  cite 900 F.3d 923 (2018)
  court United States Court of Appeals for the Seventh Circuit
  date 2018-08-20
  url catalog/cases/f3d/volume_900/0923_01/index.html
  source ir/caselaw/f3d_900.jsonl sha1=20459a2f3fef7d91bfce81f4d533e5530a1e2fab chars=26734

law 29usc623
  role applied
  posture appellate review of summary judgment in benefits liquidation case
  result claimant-lost

element neutral-practice : satisfied [law]
  scope merits
  variant benefit-liquidation/retirement-eligibility-condition
  fact @13686..13817 [supports] | Under the pension plan, retirement eligibility depends on a combination of age and a factor correlated with age (credited service).
  held @11615..11829 | Here the plaintiffs have specifically identified a cause for the disparate impact: Caterpillar's decision to condition benefits on retirement eligibility, a status strongly correlated with age. No more is required.
  gloss The court finds an identified employment practice; the later RFOA defense does not erase that finding.

element age-disparity : satisfied [law]
  scope merits
  variant statistical-impact/retirement-eligible-subgroup
  fact @13920..14081 [supports] | This is borne out by the statistics: the mean age of the retirement-eligible employees is 61.57 compared with a mean age of 47.81 for those ineligible to retire.
  fact @14167..14281 [supports] | Only 1.4% of employees under the age of 55 were eligible for retirement compared with 93.4% of those 55 and older.
  held @14282..14480 | In light of the substantial statistical disparities between the ages of retirement-eligible and nonretirement-eligible employees, the plaintiffs have established a prima facie disparate-impact case.
  gloss This is the court’s prima facie disparate-impact determination, not a final liability finding or a nationwide endorsement of every subgroup theory.

defense rfoa : satisfied [law]
  scope merits
  variant financial-purpose/eliminate-unemployment-plan-with-union-support
  fact @21196..21308 [supports] | Caterpillar also hoped to avoid the expense of upgrading the unemployment plan's outdated administration system.
  fact @21309..21491 [supports] | Recognizing that the union had resisted its prior attempts to eliminate the plan, Caterpillar offered to distribute the trust's $7.8 million to union members to secure their support.
  held @20848..20977 | Caterpillar has satisfied its burden. The liquidation plan was justified by a reasonable factor other than age-several, actually.
  gloss Reasonableness is decided on the plan rationale; this is an affirmative defense after a prima facie impact showing, not Title VII business necessity.

misfit The prima facie impact issues are satisfied while the employer’s affirmative defense defeats liability. A single case outcome must not overwrite these opposite-polarity element findings.