Maxfield v. Brigham Young University-Idaho, 27 F. Supp. 3d 1077

Maxfield, age 54, was terminated in June 2011 during a reorganization that merged two offices into the Academic Discovery Center (ADC).
Four ADC positions opened in July 2011; Maxfield applied for two but was not hired, and the four openings were filled by younger employees.
Maxfield did not receive advance notice of termination and had only two business days to apply for ADC openings; he was not transferred into the ADC.
The University retained other employees affected by the reorganization, while Maxfield’s duties largely continued to be performed by younger ADC staff.
Maxfield had 27 years of service, had previously received positive acknowledgments, and did not have a master’s degree to pursue a full-time faculty role.
The University later hired Karla LaOrange (age 51, master’s degree) to fill a Field Services Office position and hired three ADC staff under 30 in 2011-2013.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Maxfield states a prima facie ADEA claim	Maxfield shows age, satisfactory performance, discharge, and younger replacements.	Transfers and hiring were justified by internal reorganization needs and fit; no inference of discrimination.	Yes; triable issue on prima facie case due to reorganization and selective ADC integration.
Whether the University's reasons for discharge and non-transfer to the ADC are legitimate	Reasons are pretextual; younger staff absorbed duties; Maxfield uniquely affected.	Transfer difficulty and performance-based rationales justify not transferring or hiring Maxfield.	Yes; genuine issues of fact exist as to the credibility of the University's reasons.
Whether Maxfield proves pretext or discriminatory motive	Evidence undermines the University’s explanations; policy favored internal transfers; disparate treatment of older employee.	Rational explanations supported by record; no direct evidence of discriminatory intent.	Triable issues exist; pretext supported by credibility gaps and comparative treatment.
Whether Maxfield states a viable ERISA claim	Loss of future contributions due to termination affects pension rights.	ERISA claim lacks showing that termination was intended to deprive vested rights; damages issue arises under ADEA.	ERISA claim dismissed; loss of future contributions tied to ADEA damages, not a standalone ERISA claim.

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden-shifting framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (genuine issue of material fact requires evidence)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
Diaz v. Eagle Produce Ltd. Partnership, 521 F.3d 1201 (9th Cir. 2008) (flexible prima facie elements and discrimination inference)
Wells Fargo & Co. v. Wells Fargo, 902 F.2d 1422 (9th Cir. 2000) (summary judgment burden on movant; evidence standard)
Inter-Modal Rail Employees Ass’n v. Atchison, Topeka, & Santa Fe Ry. Co., 520 U.S. 510 (1997) (discrimination in retirement benefit context and entitlement)
Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (1990) (ERISA-related protections for vesting and plan rights)
Felton v. Unisource Corp., 940 F.2d 503 (9th Cir. 1991) (ERISA and discrimination interplay)
Ethridge v. Harbor House Restaurant, 861 F.2d 1389 (9th Cir. 1988) (ERISA loss of benefits as consequence, not motive)