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Kron v. Moravia Central School District
Citation: 5 F. App'x 60Docket: No. 00-7842
Court: Court of Appeals for the Second Circuit; March 11, 2001; Federal Appellate Court
The judgment of the district court, which granted summary judgment to Moravia Central School District and dismissed James H. Kron's claim under the Age Discrimination in Employment Act (ADEA), is affirmed. Kron, a guidance counselor from 1975 until his termination in June 1996, contended that his position was eliminated in violation of the ADEA. The school board cited a budget shortfall as the reason for terminating his position, which was the less senior of two guidance counselor roles. Following his termination, the school district hired a 28-year-old counselor and later hired a 45-year-old counselor, which Kron argued demonstrated age discrimination. On appeal, Kron contended that genuine issues of material fact existed and that the district court improperly rejected his expert testimony regarding the budget shortfall. However, upon de novo review, the appellate court found no genuine issues of material fact and upheld the district court's decision. The district court had assumed Kron had established a prima facie case of discrimination but determined that Moravia provided a legitimate, non-discriminatory reason for his termination. The burden then shifted back to Kron to demonstrate that this reason was merely a pretext for discrimination, which he failed to do. The court also supported the exclusion of Kron's expert testimony, finding it unreliable due to the expert's lack of relevant credentials and flawed methodology. Thus, the appellate court concluded that the district court acted within its discretion and affirmed the ruling in favor of Moravia Central School District.