In Smith v. City of Jackson (2005) 544 U.S. 228, the court held that an employer's pay plan did not violate the Age Discrimination in Employment Act of 1967 (ADEA) even though older workers received comparatively smaller pay increases, because the decision to grant a larger raise to lower echelon employees was based on a "'reasonable factor other than age.'" (Smith, supra, 544 U.S. at p. 242.) Although the plan was based on an employee's seniority and position -- factors correlated with age -- the court found no liability, because the pay differential was based upon a legitimate, nondiscriminatory reason, viz., the employer's "perceived need to raise the salaries of junior employees to make them competitive with comparable positions in the market." (Ibid.)