JEROME L. ARCHAMBAULT, PLAINTIFF-APPELLANT,
v.
UNITED COMPUTING SYSTEMS, INC., DEFENDANT-APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The court held that a finding of discrimination is reviewable only for clear error, overturning prior circuit precedent.
Plaintiff brought an age discrimination suit under the ADEA, and a magistrate served as a special master. The magistrate found discrimination, and the…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Issue Of Ultimate Fact cases and more on FLexlaw
PER CURIAM:
In this age discrimination suit brought pursuant to 29 U.S.C.A. § 626(c)(1), a magistrate served as a special master under 28 U.S.C.A. § 636(b)(2), apparently with the consent of the parties. The findings of such a special master are entitled to the same deference as those of the typical factfinder, reviewable by a district court under the clearly erroneous standard. Fed. R.Civ.P. 53(e)(2) (“[T]he court shall accept the master’s findings of fact unless clearly erroneous.”). Contrast this with the designation of a magistrate to conduct hearings under 28 U.S.C.A. § 636(b)(1) where, on objection to the magistrate’s findings, the district court must “make a de novo determination.” E.g., Nettles v. Wainwright, 677 F. 2d 404, 409 (5th Cir. Unit B 1982) (en banc).
The magistrate here made an express finding of discrimination.
The district court correctly reviewed that finding under the then law of this Circuit which provided that discrimination was an issue of “ultímate fact” to which the clearly erroneous standard of appellate review did not apply. E.g., Thompson v. Leland Police Department, 633 F. 2d 1111, 1112 (5th Cir. 1980); East v. Romine, Inc., 518 F. 2d 332, 338-39 (5th Cir.1975); Causey v. Ford Motor Co., 516 F. 2d 416, 421 (5th Cir.1975).1 Shortly thereafter, however, the Supreme Court rejected this Circuit’s approach, concluding that a finding of discrimination is reviewable only for clear error. Pullman-Standard v. Swint, 456 U.S. 273, 282, 102 S.Ct. 1781, 1787, 72 L.Ed.2d 66, 78-79 (1982).
Although Swint concerned Title VII of the 1964 Civil Rights Act, not the Age Discrimination Employment Act (ADEA), there is no reason to distinguish between findings under the two statutes for appellate review purposes. Cf. Smith v. Farah Manufacturing Co., 650 F. 2d 64, 68 (5th Cir.1981) (in a pre-Swint decision, viewing the existence of age discrimination under the ADEA as an issue of ultimate fact, like the existence of race or other discrimination under Title VII).
We therefore must remand to the district court for reconsideration of the magistrate’s finding of discrimination in light of the standard of review set forth in Swint.
VACATED AND REMANDED.
. The Eleventh Circuit, in the en banc decision of Bonner v. City of Prichard, 661 F. 2d 1206 (11th Cir.1981), adopted as precedent the decisions of the former Fifth Circuit decided prior to October 1, 1981.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Marina Cooper-Houston v. S. Ry. Co., 37 F.3d 603 (11th Cir. 1994)…strict court sat as a reviewing court and was bound to defer to the factual determinations of the magistrate judge unless those findings were clearly erroneous, and to review the legal conclusions de novo. Archambault v. United Computing Sys., Inc., 695 F. 2d 551, 552 (11th Cir.1983). The Supreme Court has held that a finding of discriminatory intent is a finding of fact and thus subject to review for clear error. Pullman-Standard v. Swint, 456 U.S. 273, 287-88, 102 S.Ct. 1781, 1789, 72 L.Ed.2d 66 (1982).…
-
Indira Gairola v. Commonwealth OF Va. Dep't OF Gen. Servs., 753 F.2d 1281 (4th Cir. 1985)…nation that Defendants Did Not Violate Title VII The factual findings of a magistrate are entitled to the same deference ujbon review as those of the trial court ui ider the clearly erroneous standard. Archambault v. United Computing Systems, Inc., 695 F. 2d 551 (11th Cir.1983). Because the inquiry regarding the existence of discriminatory intent is purely factual, the finding of a district court on discriminatory intent may be reversed only if it is clearly erroneous. Pullman-Standard v. Swint, 456 U.S. 27…
-
United States v. Farias-Gonzalez, 556 F.3d 1181 (11th Cir. 2009)…itnesses. Calderon v. Waco Lighthouse for the Blind, 630 F. 2d 352, 356 (5th Cir.1980). Rather, that review is a de novo review of the record. In re Holywell Corp., 967 F. 2d 568, 571 (11th Cir.1992); cf. Archambault v. United Computing Sys., Inc., 695 F. 2d 551, 551 (11th Cir.1983) (clear error review for findings of magistrate judge sitting as special master); United States v. Cofield, 272 F. 3d 1303, 1306 (11th Cir.2001) (district court required to rehear disputed testimony before rejecting magistrate ju…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Bonner v. City OF Prichard, 661 F.2d 1206 (11th Cir. 1981)
- Pullman-Standard v. Swint, 456 U.S. 273 (U.S. 1982)
- Ennis Nettles v. Louie L. Wainwright, 677 F.2d 404 (5th Cir. 1982)
- Cora Lee East v. Romine, 518 F.2d 332 (5th Cir. 1975)
- Causey v. Ford Motor Co., 516 F.2d 416 (5th Cir. 1975)
- Thompson v. Leland Police Dep't, 633 F.2d 1111 (5th Cir. 1980)
- Smith v. Farah Mfg. Co., Inc., 650 F.2d 64 (5th Cir. 1981)