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Keywords

appealsummary judgmentdiscriminationprobationrescission
appealsummary judgmentdiscriminationprobationrescission

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Allen v. United States Postal Service, 63 F.4th 292

Facts

Allen was hired by USPS as a city carrier assistant in April 2018, but was fired in July before her probationary period ended. After filing an EEO complaint, she was reinstated in December 2018, but her performance was deemed unacceptable, leading to her second termination in February 2019. Allen alleged that her supervisors set her up to fail and that she faced age discrimination and retaliation for her EEO activity, including the rescission of a job offer after her second termination.

In April of 2018, USPS hired Allen as a “city carrier assistant” subject to a ninety-day probationary period. At all relevant times, Allen was either fifty-three or fifty-four years old. Allen was assigned to the North Central Carrier Station (“Central Station”) in New Orleans. In July, before her probationary period lapsed, station manager Joseph Porche fired her. In August, Allen initiated Equal Employment Opportunity (“EEO”) contact regarding her termination. She alleged that USPS fired her because of her age, marital status, and disability, and also alleged a hostile work environment.

Issue

The main legal issues were whether USPS's reasons for Allen's termination were pretextual and whether the rescission of her job offer was retaliatory.

The main legal issues were whether USPS's reasons for Allen's termination were pretextual and whether the rescission of her job offer was retaliatory.

Rule

Under the ADEA, employers are prohibited from discriminating against employees based on age, and retaliation against employees for engaging in protected EEO activity is also prohibited. The court applies a burden-shifting analysis to determine if discrimination or retaliation occurred.

Under the ADEA, employers are prohibited from discriminating against employees based on age, and retaliation against employees for engaging in protected EEO activity is also prohibited. The court applies a burden-shifting analysis to determine if discrimination or retaliation occurred.

Analysis

The court found that there were genuine disputes of material fact regarding Allen's claims. Evidence suggested that USPS's reasons for her termination could be pretextual, as Allen provided detailed accounts of her supervisors' actions that undermined her performance. Additionally, the court noted that the absence of documentation supporting USPS's claims of poor performance further raised questions about the legitimacy of their reasons for termination.

The court found that there were genuine disputes of material fact regarding Allen's claims. Evidence suggested that USPS's reasons for her termination could be pretextual, as Allen provided detailed accounts of her supervisors' actions that undermined her performance. Additionally, the court noted that the absence of documentation supporting USPS's claims of poor performance further raised questions about the legitimacy of their reasons for termination.

Conclusion

The Court of Appeals reversed the district court's summary judgment on Allen's age discrimination claim related to her second termination and remanded the case for further proceedings, while affirming the dismissal of other claims.

The Court of Appeals reversed the district court's summary judgment on Allen's age discrimination claim related to her second termination and remanded the case for further proceedings, while affirming the dismissal of other claims.

Who won?

The prevailing party in the appellate court was Allen, as the court reversed the summary judgment in favor of USPS on her age discrimination claim, indicating that there were genuine issues of material fact that warranted further examination.

The prevailing party in the appellate court was Allen, as the court reversed the summary judgment in favor of USPS on her age discrimination claim, indicating that there were genuine issues of material fact that warranted further examination.

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