EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff-Appellant, v. MISSISSIPPI STATE TAX COMMISSION, Defendant-Appellee

873 F.2d 97, 1989 U.S. App. LEXIS 7098, 50 Empl. Prac. Dec. (CCH) 39,045, 49 Fair Empl. Prac. Cas. (BNA) 1393
CourtCourt of Appeals for the Fifth Circuit
DecidedMay 22, 1989
Docket87-4659
StatusPublished
Cited by3 cases

This text of 873 F.2d 97 (EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff-Appellant, v. MISSISSIPPI STATE TAX COMMISSION, Defendant-Appellee) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff-Appellant, v. MISSISSIPPI STATE TAX COMMISSION, Defendant-Appellee, 873 F.2d 97, 1989 U.S. App. LEXIS 7098, 50 Empl. Prac. Dec. (CCH) 39,045, 49 Fair Empl. Prac. Cas. (BNA) 1393 (5th Cir. 1989).

Opinions

REAVLEY, Circuit Judge:

The Equal Employment Opportunity Commission (EEOC) challenges the mandatory retirement at age 60 of Mississippi State Tax Commission scales enforcement officers. The district court found age to be a bona fide occupational qualification, justifying the mandatory retirement state law1 within the Age Discrimination in Employment Act.2 The work of these officers who enforce Mississippi revenue laws pertaining to commercial vehicles and highways is explained in the court’s opinion at 693 F.Supp. 516. A panel of this court reversed the judgment and. remanded for back pay determinations, holding that the Mississippi Commission failed to establish that physical fitness was an occupational qualification in the absence of any minimum standards or any attempt to monitor employees’ health and fitness. 848 F.2d 526, 530. The en banc court declines to hold that physical fitness can never be held to be reasonably necessary for job performance unless the employer has established formal standards and monitoring procedures, but we believe the district court incorrectly failed to consider all of the evidence on the issue. We vacate the judgment and remand for further consideration.

I.

To qualify under the BFOQ exception to the ADEA, an employer must show: (1) The job qualifications invoked to justify the age discrimination must be reasonably necessary to the normal operation of the particular business, and (2) age is a necessary proxy for those job qualifications, either because (a) there is a factual basis for believing that all or substantially all people over a certain age would be unable to satisfy those job qualifications, or (b) there is proof that individual testing for those job qualifications is impossible or highly impractical. Western Air Lines v. Criswell, 472 U.S. 400, 413-15, 105 S.Ct. 2743, 2751-52, 86 L.Ed.2d 321 (1985); Usery v. Tamiami Trail Tours, Inc., 531 F.2d 224, 235 (5th Cir.1976).

Some courts hold that an employer is precluded from making the first showing, i.e., that the age related qualification is necessary, by a failure to develop, implement, and enforce minimum standards for that qualification. See EEOC v. Commonwealth of Pennsylvania, 829 F.2d 392, 395 (3d Cir.1987), cert. denied, — U.S. —, 108 S.Ct. 1109, 99 L.Ed.2d 271 (1988); accord EEOC v. Kentucky State Police Dept., 860 F.2d 665, 668-69 (6th Cir.1988). Other courts treat the enforcement, or lack of enforcement, of minimum standards as evidence — giving it different probative value — on the issue of the necessity of the asserted job qualifications. See EEOC v. Missouri State Highway Patrol, 748 F.2d 447, 454 (8th Cir.1984), cert. denied, 474 U.S. 828, 106 S.Ct. 88, 88 L.Ed.2d 72 (1985) (“Moreover, the relevance of a physical fitness program to the issues ... is questionable.”); EEOC v. New Jersey, 631 F.Supp. 1506, 1508 (D.N.J.1986), aff'd, 815 F.2d 694 (3d Cir.1987) (the police department’s commitment to maintaining the continued health and fitness of its officers forecloses any serious dispute that those qualifications are essential to the safe and efficient performance of their duties); EEOC v. City of East Providence, 798 F.2d 524, 530-31 (1st Cir.1986) (“low physical standards, coupled with other factors, might persuade a district court that physical fitness was not deemed a necessary job qualification” by that employer); Heiar v. Crawford County, Wis., 746 F.2d 1190, [99]*991198-99 (7th Cir.1984), cert. denied, 472 U.S. 1027, 105 S.Ct. 3500, 87 L.Ed.2d 631 (1985) (“[i]f Crawford County required [periodic physical exams or fitness tests] it could argue (we need not decide with what success) that this showed the genuineness of its concern with the physical fitness of its deputy sheriffs”).

A prior panel of this circuit drew upon the Third Circuit’s writing when it affirmed the district court’s rejection of Mississippi’s mandatory retirement age for game wardens. EEOC v. Mississippi, 837 F.2d 1398 (5th Cir.1988). We do not disagree with that panel, and the trial judge, in stressing the weight of standards of health and fitness in the fact determination; we only say that physical fitness may be a job qualification despite the lack of formal standards. The weight to be given the existence or absence of formal standards is for the fact finder to decide, with its finding subject to the appropriate appellate review on the entire record. The Criswell opinion emphasizes the importance of fact finding on a “case-by-case basis” under the ADEA structure. 105 S.Ct. at 2755.

II.

To satisfy the first prong of the Tamia-mi test, the district court found: “that the MSTC has clearly established that physical stamina and the ability to withstand the stressful working conditions are essential to the safe and efficient execution of the duties of a Scales Enforcement Officer.” 693 F.Supp. at 526. In view of the failure of the court to discuss the evidence supporting the EEOC’s contention that health and fitness were in fact ignored by the Commission, the stated finding may refer to an ideal scales officer force — or what might be done — rather than the operation Mississippi actually has in place. The Chairman of the Mississippi State Tax Commission insisted that the officers are required to be physically fit in order to perform their tasks, and the Commission presented substantial evidence of tasks and challenges which could be managed only by officers with stamina and the ability to handle stress. The difficulty with the evidence and the district court’s finding is not only that the Commission had no periodic physical examinations or fitness tests. The EEOC elicited testimony that scales enforcement officers, on the whole, fail to exemplify the type of employee the Commission contends is required for the job. An expert witness called by the EEOC, Dr. Arthur Leon, stated his opinion that a quarter of the employees are overweight, over two-thirds smoke cigarettes, few exercise, and quite a few have serious medical problems. Among the medical problems of current employees under retirement age are diabetes, orthopedic problems, mental problems, and high blood pressure. The district court did not discuss this evidence and may have confused the distinct inquiries raised under the two separate prongs of the Tamiami test. If so, the district court is not alone. See Missouri State Highway Patrol, 748 F.2d at 454; cf Heiar, 746 F.2d at 1198 (the court’s simultaneous treatment of both prongs of the BFOQ inquiry prompts confusion from its discussion of minimum standards and of impossible or impracticable individual testing).

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873 F.2d 97, 1989 U.S. App. LEXIS 7098, 50 Empl. Prac. Dec. (CCH) 39,045, 49 Fair Empl. Prac. Cas. (BNA) 1393, Counsel Stack Legal Research, https://law.counselstack.com/opinion/equal-employment-opportunity-commission-plaintiff-appellant-v-ca5-1989.