O'Brien v. Caterpillar Inc.
appellate review of summary judgment in benefits liquidation case (result: claimant-lost)
Facts
- 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.
- 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).
- 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.
- 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.
- 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.
- 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.
- 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Caterpillar also hoped to avoid the expense of upgrading the unemployment plan's outdated administration system.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 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.