Announcing several important holdings in age discrimination and ERISA law, the 3rd U.S. Circuit Court of Appeals yesterday refused to revive the claims of 17 Conrail workers who said they were targeted for layoffs in 1995 because Conrail was worried about its “aging workforce” and also wanted to deprive them of the chance to take advantage of early-retirement packages that were offered the following year.
Significantly, the unanimous three-judge panel in Anderson v. Conrail upheld U.S. District Judge Harvey Bartle III’s use of a stricter test for assessing whether a plaintiff in a reduction-in-force case had made out a prima facie case of age discrimination.
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