In Lytle v. Malady (On Rehearing), 458 Mich 153, 177; 579 NW2d 906 (1998), the Supreme Court rejected the plaintiff's evidence, finding that the comparison to younger employees who were not terminated was flawed for two reasons: first, because the other employees were not similarly situated to the plaintiff "in terms of job qualifications and functions," and second, because the individual responsible for eliminating the plaintiff's position did not take part in the decision to hire or retain the other employees. Id. at 179. The Court held that to establish a prima facie case of age discrimination, the plaintiff must show that: (1) he was a member of a protected class; (2) he was discharged; (3) he was qualified for the position; (4) he was replaced by a younger person. A plaintiff must present sufficient evidence to raise a triable issue of fact that his position would not have been eliminated but for his age. Id. An age discrimination claim can be based on two theories: (1) disparate treatment, which requires a showing of either a pattern of intentional discrimination against protected employees, e.g., employees aged forty to seventy years, or against an individual plaintiff, or; (2) disparate impact, which requires a showing that an otherwise facially neutral employment policy has a discriminatory effect on members of a protected class. Meagher v. Wayne State Univ, 222 Mich App 700, 708-709; 565 NW2d 401 (1997); Farmington Ed Ass'n v. Farmington School Dist, 133 Mich App 566; 351 NW2d 242 (1984). To establish a claim for disparate treatment, a plaintiff must show that he was treated differently from similarly situated employees. Lytle, supra at 178.