Liebman v. MetLife Ins. Co., No. 14-13197 (11th Cir. 2015)
Annotate this CasePlaintiff filed suit against his former employer, MetLife, alleging claims of age discrimination under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623(a)(1), as well as a retirement benefits interference claim under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. The district court granted summary judgment for MetLife. The court concluded that plaintiff has established a prima facie case of discrimination under the ADEA where plaintiff was replaced by someone substantially younger, plaintiff was qualified for the job for which he was discharged, and the justifications offered for plaintiff's termination were not a proper basis for rejecting plaintiff's prima facie showing. The court vacated the district court's order as to this claim and remanded for reconsideration of whether summary judgment is appropriate under the McDonnell Douglas framework. The court also concluded that the district court erred in granting judgment in favor of MetLife before deciding on the admissibility of certain declarations. Accordingly, the court vacated the grant of summary judgment as to this issue and remanded for the district court to rule on the admissibility of the declarations.
The court issued a subsequent related opinion or order on September 8, 2017.
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