Today the U.S. Supreme Court issued four labor and employment-related decisions; none, however, were big surprises or substantial changes in the law.

 First, in Meacham v. Knolls Atomic Power Laboratory, the Court held 8-0 that an employer defending an Age Discrimination in Employment Act case bears the burden of proving a "reasonable factors other than age" or "RFOA" affirmative defense.  Truth be told, most defense lawyers have assumed that it was the employer’s burden to prove the affirmative defense; this decision simply confirms that assumption. 

Second, in Chamber of Commerce v. Brown, the Court ruled 7-2 that federal labor law preempts California Gov’t Code Section 16645.2, which prohibits private employers who are "recipient[s] of a grant of state funds" from "us[ing] the funds to assist, promote, or deter union organizing."  Again, not a big surprise. 

Next, in Kentucky Retirement Systems v. EEOC, the Court held 5-4 that a disability-retirement-benefits plan for public employees did not violate the Age Discrimination in Employment Act (ADEA).  The plan  disqualifies employees who are still working from receiving benefits if they reach normal retirement age when they become disabled, and calculates disability retirement benefits so that older employees who is eligible for disability benefits receive fewer benefits than younger employees.  The Court held that any differential treatment was not based on age, but rather on pension status. 

Finally, in Metropolitan Life Insurance v. Glenn, the Court held 7-2 that an ERISA plan administrator’s dual role of both evaluating and paying benefits claims creates a conflict of interest, and courts reviewing claims denials can properly consider that conflict in deciding to set aside the administrator’s discretionary decision.