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Caruso v. Alltel Corp.

Citation: 113 F. App'x 90Docket: No. 03-4047

Court: Court of Appeals for the Sixth Circuit; September 23, 2004; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by an employee who alleged age discrimination under the Age Discrimination in Employment Act (ADEA) against his former employer, following over three decades of service. The central legal issue revolved around the timeliness of the employee's filing with the Equal Employment Opportunity Commission (EEOC). After being orally notified of his termination on September 27, 1999, and receiving written confirmation on November 15, 1999, the employee filed his EEOC charge on December 6, 2000. Under ADEA, he was required to file within 300 days of the notification due to Ohio being a deferral state, which he failed to do. The district court granted summary judgment to the employer, ruling the claim was time-barred, as it was filed after the lapse of the 300-day period. The appellate court conducted a de novo review of this summary judgment and affirmed the district court's decision, determining that the complaint's untimeliness precluded consideration of its merits. Consequently, the employee's claim was dismissed, upholding the employer's summary judgment victory.

Legal Issues Addressed

Summary Judgment Review Standard

Application: The appellate court applied a de novo review standard to the district court's grant of summary judgment, affirming the decision without considering the underlying ADEA claim merits.

Reasoning: The appellate court reviewed the summary judgment de novo and affirmed the district court's decision, concluding that Caruso's complaint was indeed time-barred.

Time Limitation for Filing an ADEA Claim

Application: The court examined the timeliness of the ADEA claim, emphasizing the requirement to file a charge within 300 days of the alleged discriminatory act in a deferral state like Ohio.

Reasoning: He had until February 9, 2000, to file his charge, as he was required to do so within 300 days of the alleged discriminatory act in Ohio, a deferral state.