Mount Lemmon Fire District v. Guido

The Mount Lemmon Fire District in Arizona terminated its two oldest full-time firefighters, John Guido and Dennis Rankin, who were 46 and 54 years old at the time. They sued the district for age discrimination under the Age Discrimination in Employment Act (ADEA). The fire district argued it was not an "employer" subject to the ADEA because it had fewer than 20 employees. The ADEA's definition of employer includes a person with 20 or more employees and also "any agent of a State or political subdivision." The key question was whether the 20-employee minimum applies to political subdivisions. The U.S. Supreme Court unanimously held that it does not, meaning state political subdivisions are covered by the ADEA regardless of their number of employees. Justice Ruth Bader Ginsburg delivered the opinion, resolving a split among the federal appellate courts.

The U.S. Supreme Court ruled unanimously that the ADEA's 20-employee threshold does not apply to state political subdivisions. The ADEA covers all state and local government employers, including the Mount Lemmon Fire District, regardless of the number of employees. The lower court's judgment was affirmed.

Whether the 20-employee minimum in the Age Discrimination in Employment Act's definition of "employer" applies to political subdivisions of a state, or whether all such subdivisions are covered regardless of size.

The decision clarified that small public employers, such as rural fire districts and local boards, are not exempt from the Age Discrimination in Employment Act. It strengthened age discrimination protections for public employees nationwide, ensured uniform enforcement of the ADEA, and resolved a long-standing circuit split on this issue.