Where a defendant employer was awarded summary judgment on a claim of age discrimination asserted by a plaintiff who was laid off in a reduction in force, that judgment must be vacated because the plaintiff produced sufficient evidence to create a dispute of fact regarding whether he was terminated due to discriminatory animus.
“Mark Adams sued his former employer, Schneider Electric USA (Schneider Electric), for age discrimination after he was laid off in a 2017 reduction in force. Schneider Electric was granted summary judgment by the Superior Court, and the Appeals Court, in a divided decision, reversed. We granted further appellate review to clarify the summary judgment standards in employment discrimination cases, including the correct application of the ‘cat’s paw’ theory of liability and the ‘stray remarks’ doctrine.
“Adams was fifty-four years old at the time of the layoff. He had been an electrical engineer in the research and development (R&D) group of the home and business networks (HBN) division of the company in Andover since 2007, when Schneider Electric acquired his previous employer.
“Adams produced evidence that officials at Schneider Electric wanted to increase ‘age diversity’ in the company in general, and the HBN R&D group in particular, by hiring recent college graduates and reducing the number of older employees. Consistent with this policy, Adams’s R&D group in Andover was targeted for reductions in force while a younger R&D group in...
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