Laura Holtz v. Rockefeller & Co., Inc.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Gross v. FBL Financial Services, Inc. displaced Holtz's statement that age need only play a motivating role in an ADEA decision: an ADEA plaintiff must prove but-for causation. Holtz's other employment discrimination and procedural holdings survive. The confirmed treatment is listed below.
1,375 later cases cite Laura Holtz v. Rockefeller & Co., Inc.; 123 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Laura Holtz v. Rockefeller & Co., Inc.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Abrogated
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The Supreme Court displaced Holtz's ADEA motivating-role standard with a but-for causation requirement.
Gross v. FBL Financial Services, Inc. · Supreme Court of the United States · filed
To establish a disparate-treatment claim under the plain language of the ADEA, therefore, a plaintiff must prove that age was the “but-for” cause of the employer’s adverse decision.
Read the full opinion on CourtListener →
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