Lee v. Trw, Inc.

MEMORANDUM

Edward Lee (“Lee”) filed suit against TRW Inc. (“TRW”) for age discrimination in violation of California’s Fair Employment and Housing Act (“FEHA”). Following a trial in district court, the jury found TRW liable under the FEHA, and the jury awarded compensatory and punitive damages to Lee. TRW now appeals the district court’s denial of TRW’s post-verdict Rule 50(b) motion for judgment as a matter of law. We affirm.

In 1999, Lee was laid off from TRW after more than twenty years of employment with the company. At the time of his layoff, Lee was a test engineer in the Electronic Products Organization (“EPO”), a department within TRW’s Electronic Products Center (“EPC”). There were seven test engineers within EPO who were considered for the layoff, and Lee was the oldest.

The head of the EPO, Paul Nakamura (“Nakamura”), oversaw the layoff process. In executing the layoff, Nakamura worked with Rick Eriksen and Steve Mass, two subordinate managers, and with John Mol-is (“Molis”), the acting section head for test engineers in the EPO. Molis was assigned the task of designing a “skills matrix” to evaluate the seven test engineers and recommend a layoff candidate. Lee was…