United States District Court for the Eastern District of Tennessee · 2019-03-18
29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
Role: applied; posture: civil; ADEA age discrimination; employer motion for summary judgment denied by ED Tenn; result: claimant-won; claim:
Uncertainty
None recorded
Misfit
None recorded
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 31
| Case | Employer coverage and exclusions | Age forty or older | Hiring discharge or employment terms | Judicial but-for standard for age-based treatment | Route-conditioned statutory f(1) and f(2) alternatives | Conditional state firefighter and law-enforcement hiring or retirement |
|---|---|---|---|---|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 31
| Case | Age sixty-five executive or high-policymaker compulsory retirement | Judicial impact requirement to identify a particular practice | Judicial impact requirement of significant causal disparity | Covered employment agency | Covered labor organization | Opposition or participation |
|---|---|---|---|---|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 13–18 of 31
| Case | Judicial material-adversity standard for retaliation | Retaliatory causal connection | Agency referral discrimination | Membership classification referral or causing discrimination | Employer agency or union advertiser | Age-based notice or advertisement |
|---|---|---|---|---|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 19–24 of 31
| Case | Wage reduction to comply | Employer agency union or combination maintaining a pension plan | Establish or maintain an employee pension benefit plan | Age-based accrual or allocation cessation or reduction | Subsection i pension qualifications and compliance | Conditional bona fide seniority system or benefit plan |
|---|---|---|---|---|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 25–30 of 31
| Case | Narrow bona fide occupational qualification | Displayed scope and specialized exclusions | Charge filing waiver and remedies | Foreign workplace conflict with local law | Good cause for employer discharge or discipline | Judicial outside-applicant coverage limit where circuit precedent controls |
|---|---|---|---|---|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 31–31 of 31
| Case | Reasonable factors other than age |
|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 — satisfied · triable (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Judicial but-for standard for age-based treatment | satisfied Counted merits instance applied / merits basis: triable | disputed-misconduct-complaint-plus-retirement-inquiries-and-undisciplined-younger-comparator | Richardson also testified that two or three days before her termination, McMahan asked when she was going to retire, noting that she was about to be seventy years old.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [14003:14170] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.Astec does not point to any evidence suggesting that Oswald was not expected to comply with Astec's core values or that McMahan subsequently disciplined him for his alleged conduct.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [35150:35331] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.Additionally, Richardson has submitted a declaration from Debbie Daugherty in which she avers that Richardson never made her cry and that she refused to report Richardson to human resources despite Oswald's urging.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [37722:37936] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.McMahan maintains any questions about Richardson's retirement plans were solely for purposes of succession planning, citing the need to ensure that certain responsibilities were covered in the event an employee resigned, retired, or otherwise ended their employment relationship with Astec.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [14294:14584] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.An employee can demonstrate pretext by providing evidence that the employer's reason for terminating her: (1) had no basis in fact; (2) did not actually motivate the discharge; or (3) was insufficient to motivate the discharge.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [36302:36529] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.Accordingly, Richardson has provided sufficient evidence from which a reasonable jury could conclude that Astec's stated reason for firing Richardson was actually pretext for age discrimination.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [38667:38861] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94. |
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 — satisfied · conceded (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Hiring discharge or employment terms | satisfied Counted merits instance applied / merits basis: conceded | employer-terminated-worker | On January 16, 2017, after Oswald submitted his complaint, McMahan and Oswald met with Locklear and, at the conclusion of the meeting, decided to terminate Richardson's employment.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [12438:12618] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.The parties do not dispute that Richardson is a member of a protected class, that she suffered an adverse employment action, or that she was qualified for the position she held.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [33413:33590] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94. |
| Richardson v. Astec, Inc. — 366 F. Supp. 3d 983 (2019) · United States District Court for the Eastern District of Tennessee · 2019 — satisfied · conceded (29usc623: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Age forty or older | satisfied Counted merits instance applied / merits basis: conceded | worker-over-forty | Richardson was seventy years old when Astec terminated her.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [12642:12701] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94.The parties do not dispute that Richardson is a member of a protected class, that she suffered an adverse employment action, or that she was qualified for the position she held.Source: docroot/ir/caselaw/f_supp_3d_366.jsonl#/f-supp-3d/366/0983-01; Unicode character offsets [33413:33590] (end exclusive); SHA-256 58eda9414a4fe9f2012d19b3411a56611a06836293a830dc45acfba99af15f94. |