In Martinez v. UPMC Susquehanna, the U.S. Court of Appeals for the Third Circuit clarified the specificity required in pleading prima facie cases of discrimination in light of the holdings in Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atlantic v. Twombly, 550 U.S. 544 (2007). The Third Circuit held that an age discrimination plaintiff need not plead the exact age or duties of the plaintiff's alleged replacement in order to survive a motion to dismiss.

The plaintiff in the Martinez case appealed an order issued by the U.S. District Court for the Middle District of Pennsylvania dismissing the case for failure to state a claim under Iqbal and Twombly. The defendant, UPMC Susquehanna, employed the plaintiff, Dr. Zeferino Martinez, as an orthopedic surgeon. Martinez alleged in his complaint that UPMC Susquehanna terminated his employment and advised him that it was "moving in a different direction and his services were no longer needed." UPMC Susquehanna also told Martinez that his termination had "nothing to do with his performance." Martinez pleaded that he was 70 years old, and that UPMC Susquehanna hired two doctors after his termination. The complaint alleged that one of the hired physicians took over some of Martinez's job duties, and that the second doctor was hired in response to a job posting for an orthopedic surgeon. Relevant to the court's analysis, Martinez alleged that both doctors were "significantly younger," "less qualified" and "less experienced" than Martinez.