O'Brien v. Caterpillar Inc.

900 F.3d 923 (2018) United States Court of Appeals for the Seventh Circuit 2018-08-20

appellate review of summary judgment in benefits liquidation case (result: claimant-lost)

Facts

  1. 5 Judicial impact requirement to identify a particular practice satisfied law
    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.
  2. 5 Judicial impact requirement to identify a particular practice satisfied law
    Under the pension plan, retirement eligibility depends on a combination of age and a factor correlated with age (credited service).
  3. 6 Judicial impact requirement of significant causal disparity satisfied law
    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.
  4. 6 Judicial impact requirement of significant causal disparity satisfied law
    Only 1.4% of employees under the age of 55 were eligible for retirement compared with 93.4% of those 55 and older.
  5. 6 Judicial impact requirement of significant causal disparity satisfied law
    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.
  6. 8 Reasonable factors other than age satisfied law
    Caterpillar has satisfied its burden. The liquidation plan was justified by a reasonable factor other than age-several, actually.
  7. 8 Reasonable factors other than age satisfied law
    Caterpillar also hoped to avoid the expense of upgrading the unemployment plan's outdated administration system.
  8. 8 Reasonable factors other than age satisfied law
    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.