The First Circuit recently decided a Massachusetts state law age
discrimination case that provides employers with several important
reminders. In Woodward v. Emulex, the court affirmed a
district court decision granting summary judgment for the defendant
on a plaintiff's age discrimination claim and also affirmed the
district court's rulings on two discovery motions.
The plaintiff, Frank Woodward, was a sales account manager for
defendant Emulex Corporation, a California-based technology
company. Though plaintiff and his team outperformed sales goals and
received praise for their work for several years, the team's
revenues eventually began to decline and, in 2009, Emulex
terminated plaintiff's employment. Plaintiff, 55 years old at
the time of his termination, brought suit, alleging that the
company's explanation for his termination—i.e., his
team's declining revenues—was merely a pretext for age
discrimination.
