Hazen Paper Co. v. Biggins

In Hazen Paper Co. v. Biggins, 507 U.S. 604, 610-13, 123 L. Ed. 2d 338, 113 S. Ct. 1701 (1993), the Court reiterated that "a disparate treatment claim cannot succeed unless the employee's protected trait actually played a role ... and had a determinative influence" on the employer's decision or action. 507 U.S. at 610. Because "an employee's age is analytically distinct from his years of service," id. at 611, the Court held that "there is no disparate treatment under the ADEA when the factor motivating the employer is some feature other than the employee's age," id. at 609, although such factors may correlate with age, including seniority, wage rates or pension status. Id. at 611-13.