Mount Lemmon Fire Dist. v. Guido
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Mount Lemmon Fire Dist. v. Guido and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Mount Lemmon Fire Dist. v. Guido.
The Supreme Court affirmed that the Age Discrimination in Employment Act (ADEA) applies to states and political subdivisions regardless of their size. The Court interpreted the phrase 'also means' in the ADEA's definitional provision as additive, extending the Act's reach beyond entities with 20 or more employees. This interpretation aligns the ADEA with the Fair Labor Standards Act (FLSA) rather than Title VII.
Holding
The single most important “bottom line” of what the Court decided in Mount Lemmon Fire Dist. v. Guido.
The Court held that the ADEA applies to states and political subdivisions without a numerosity limitation.
Constitutional Concepts
These are the Constitution-related themes that appear in Mount Lemmon Fire Dist. v. Guido. Click a concept to see other cases that involve the same idea.
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Why Commerce Clause is relevant to Mount Lemmon Fire Dist. v. Guido
The case involves the interpretation of the ADEA's applicability to states and political subdivisions, which affects entities engaged in commerce.
Syllabus excerpt (verbatim)persons engaged in an industry affecting commerce with 20 or more employees; and States or political subdivisions with no attendant numerosity limitation.
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Why State–Federal Power is relevant to Mount Lemmon Fire Dist. v. Guido
The case discusses the applicability of federal law (ADEA) to state and political subdivisions, implicating the balance of state and federal authority.
Syllabus excerpt (verbatim)Reading the ADEA's definitional provision, § 630(b), as written to apply to States and political subdivisions regardless of size may give the ADEA a broader reach than Title VII.
Key Quotes
Short excerpts from the syllabus in Mount Lemmon Fire Dist. v. Guido that support the summary and concepts above.
The words 'also means' in § 630(b) add new categories of employers to the ADEA's reach.
Reading the ADEA's definitional provision, § 630(b), as written to apply to States and political subdivisions regardless of size may give the ADEA a broader reach than Title VII.
The Equal Employment Opportunity Commission has, for 30 years, interpreted the ADEA to cover political subdivisions regardless of size.
