Venita Billingslea v. Michael Astrue, 502 F. App'x 300

Before Motz, King, and Shedd, the court affirmed a district court grant of summary judgment for the SSA on Billingslea's ADEA claim.
Billingslea alleged she was not promoted due to age; the SSA provided legitimate, non-discriminatory reasons for selecting a younger employee.
The district court applied the McDonnell Douglas burden-shifting framework to analyze the ADEA claim.
The court reviewed whether the SSA's proffered reasons were pretextual and whether the selecting official relied on those reasons.
The court found no genuine dispute about material facts showing pretext or age-based discrimination and affirmed.
Notes indicate Billingslea forfeited review of gender and marital status claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Billingslea proved a prima facie ADEA case and pretext.	Billingslea contends shifting justifications show discrimination.	Astrue argues the reasons are legitimate and non-discriminatory.	No triable dispute; no pretext shown.
Whether the SSA's stated reasons for selecting a younger employee were pretextual.	Billingslea argues reasons are false and indicative of bias.	SSA's reasons were consistent and credible.	Not shown; reasons deemed legitimate.
Whether evidence from SSA employees about discriminatory practices creates a triable issue.	Testimony supports discrimination claim.	Testimony too speculative to oppose summary judgment.	Insufficient to defeat summary judgment.

Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (ultimate question is whether plaintiff was victim of intentional discrimination; burden to prove but-for cause (pretext analysis))
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes burden-shifting framework for discrimination claims)
Holland v. Wash. Homes, Inc., 487 F.3d 208 (4th Cir. 2007) (pretext analysis depends on probative value of employer's false justification)