Failure To Train about Age Discrimination Results in Employer Liability

January 2002

In this article, Paul Siegel examines a recent ruling by the Seventh Circuit holding an employer liable for $50,000 for age discrimination and lists ways employers can avoid harassment and discrimination claims.

by Paul J. Siegel, Esq.
Jackson, Lewis, Schnitzler & Krupman

On October 15, 2001, the Seventh Circuit Court of Appeals affirmed a district court ruling that an automobile dealership which could not demonstrate that it trained its hiring managers about age discrimination was liable for $50,000 in liquidated damages for its "willful" violation of the Age Discrimination in Employment Act (ADEA) (in addition to $50,000.00 in compensatory damages). Mathis v Phillips Chevrolet, Inc., 2001 U.S. App LEXIS 21879 (7th Cir October 15, 2001).

The underlying facts are as follows. In response to an employment advertisement, Anthony Mathis, a 59-year-old African American man with over 24 years of car sales experience, applied for a salesman position by leaving an employment application with a cashier at Phillips. When he was not contacted within a few weeks, Mathis returned to the car dealership and submitted a second application.

The application form asked for the year of Mathis's discharge from the military, to which Mathis indicated "1959." This disclosure alerted Phillips to the fact that Mathis was well over 40 years of age. Phillips never interviewed Mathis for the sales position. However, subsequent to the submission of Mathis's applications, Phillips hired seven other applicants, who all were Caucasian and younger than Mathis.

Mathis sued claiming age and race discrimination in violation of the ADEA and Title VII of the 1964 Civil Rights Act. A jury found for the dealership on the race discrimination claim, but found for Mathis on the age discrimination claim and awarded him liquidated damages due to the employer's "willful" violation of the ADEA.1 Mathis established that the general manager, who made the final hiring decisions, often noted applicants' ages on the application in the area where he recorded pertinent hiring information. In addition, the general manager testified he was not aware that basing employment decisions on age was illegal. Further, a second Phillips manager admitted at trial that he looked to hire applicants who were "bright, young, and aggressive."

In finding that the age discrimination was willful, the jury rejected Phillip's argument that the equal employment opportunity (EEO) statements on the employment application was a good faith attempt to comply with the law and did not believe the dealership's managers, who testified that they did not receive Mathis's application.

The Seventh Circuit affirmed the district court's ruling. In addressing the issue of whether Phillips's violation of the ADEA was willful, which would justify double-damages, the Seventh Circuit cited the Supreme Court's holding in Hazen Paper that a violation will be considered willful, "if an employer knew or showed reckless disregard for the matter of whether its conduct, or the conduct of its employees, was prohibited by the ADEA."

The Seventh Circuit further stated, "leaving managers with hiring authority in ignorance of the basic features of the discrimination laws is an "extraordinary mistake" for a company to make, and a jury can find that such extraordinary mistakes amount to reckless indifference." This "indifference" justifies an award of liquidated damages.

In addressing Phillips's argument that its actions were not willful because its employment application stated that the ADEA prohibits discrimination against applications on the basis of age, the Seventh Circuit concluded that such evidence is more harmful than helpful. The court stated that, "because the jury could easily have concluded that printing this statement on the application but then making no effort to train hiring managers about the ADEA shows that Phillips knew what the law required but was indifferent to whether its managers followed the law."

To avoid liability for liquidated damages, employers should follow the advice offered by the Supreme Court in its Kolstad ruling about punitive damages. Briefly stated, an employer has an affirmative defense to prove that it has made ongoing and effective efforts to avoid harassment and discrimination. Those efforts can include supervisory training; employee education about antidiscrimination programs; adoption of preventive policies; implementation of effective problem-resolution; posting of the employer's zero-tolerance policy prohibiting harassment; and additional preventive programs.


1Under the ADEA, liquidated damages are a monetary award equal to the prevailing plaintiff's economic recovery (e.g., lost wages and benefits).


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