Public Employees Retirement System of Ohio v. Betts’s Empirical Analysis
1989
Citation profile
332 federal appellate · 72 district · 23 state decisions
How this case has been cited
Cited by 730 later decisions (30 by the Supreme Court) — most recently March 2019 · most notably Central Bank of Denver Na v. First Interstate Bank of Denver Na K (1994), Gregory v. Ashcroft (1991)
332 federal appellate · 72 district · 23 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedBetts v. Hamilton County Board of Mental Retardation & Developmental Disabilities (from Sixth Circuit Court of Appeals)
Relationships
Applies 29 U.S.C. § 1002 (§ 3 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1053 (§ 203 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 621 (§ 2 of the Age Discrimination in Employment Act of 1967) · 29 U.S.C. § 623 (§ 4 of the Age Discrimination in Employment Act of 1967) · 29 U.S.C. § 630 (§ 11 of the Age Discrimination in Employment Act of 1967) · 42 U.S.C. § 2000E (§ 703 of the Title VII of the Civil Rights Act of 1964)
Relies on Celotex Corporation v. Catrett H · Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Blum v. Stenson · Consumer Product Safety Commission v. GTE Sylvania, Inc. · Bowen v. Georgetown University Hospital
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 730 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“According to the Court [in Betts], § 4(f)(2) provided a broad exemption for employee benefit plans under the ADEA, and therefore the general prohibitions regarding the unlawfulness of discrimination against older employees found in § 4(a)(1) did not apply to employee benefit plans.... ... [T]he Court rejected the'‘equal benefit or equal cost’ principle by determining that an employer need not demonstrate a legitimate cost justification for age-based reductions in benefits.... Instead, the Court required an employee to prove that the challenged plan intended to serve the purpose of discriminating in some non-fringe-benefit aspect of the employment relation, such as hiring, firing and wages, in order to establish an ADEA violation. This interpretation would effectively validate virtually all age-based restrictions in [employee benefit plans] absent the requisite showing by an employee that the employer subjectively intended to discriminate.”
18 later decisions quote this exact passage · from the concurrence“It shall not be unlawful for [a state or local government] to ... discharge any individual [law enforcement officer or firefighter] because of such individual’s age if such action is taken ... (2) pursuant to a bona fide hiring or retirement plan that is not a subterfuge to evade the purposes of this chapter.”
15 later decisions quote this exact passage · from the majority“any bona fide employee benefit plan ... which is not a subterfuge to evade the purposes of the Act”
14 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.