Reasonableness Standard for Performance-Based Terminations under the ADA and ADEA

Introduction

Charles Carroll v. IDEMIA Identity & Security USA, No. 23-6075 (6th Cir. Apr. 7, 2025), is a published Sixth Circuit decision affirming summary judgment for an employer in an age- and disability-discrimination suit and a contractual severance dispute. Charles Carroll, Senior Vice President of Enrollment Services at IDEMIA, oversaw both TSA’s PreCheck contract and a new biometric initiative called “Trusted Fan.” After protracted negotiations over a reassignment and compensation, IDEMIA terminated Carroll for underperformance and alleged misconduct. Carroll sued under the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), and for breach of contract under Tennessee law. The district court granted summary judgment to IDEMIA on all counts, and the Sixth Circuit affirmed.

Summary of the Judgment

ADA Claim: Carroll argued that his termination was motivated by his prostate-cancer diagnosis. The panel assumed a prima facie case but held that IDEMIA offered a legitimate, non-discriminatory reason—Carroll’s poor leadership of Trusted Fan—and that Carroll failed to show pretext. His alternative pretext theories (unreasonableness of the firing, stray health-related comments, temporal proximity) were insufficient.
ADEA Claim: Carroll relied on isolated age-related remarks by executives. The court found these stray comments too ambiguous and disconnected from the firing to prove but-for causation of age discrimination.
Breach of Contract: Carroll’s employment agreement guaranteed severance unless termination was for “performance or gross misconduct.” IDEMIA proved it fired him for poor performance. Carroll offered no evidence of another motivating reason, so the severance-pay claim failed.

Analysis

Precedents Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973): Established burden-shifting for circumstantial discrimination claims.
Majewski v. Automatic Data Processing, Inc., 274 F.3d 1106 (6th Cir. 2001): Articulated the “honest-belief” rule for an employer’s nondiscriminatory explanation.
Hartsel v. Keys, 87 F.3d 795 (6th Cir. 1996): Defined the standard for when a business decision is so deficient that it warrants inference of pretext.
Babb v. Maryville Anesthesiologists P.C., 942 F.3d 308 (6th Cir. 2019): Distinguished reasonable-decision pretext challenges from attacks on the facts underlying the decision.
Rosebrough v. Buckeye Valley High Sch., 690 F.3d 427 (6th Cir. 2012): Clarified elements of an ADA prima facie case.
Scheick v. Tecumseh Public Schools, 766 F.3d 523 (6th Cir. 2014): Emphasized but-for causation in ADEA claims.

Legal Reasoning

1. Burden-Shifting Framework
The court applied the McDonnell Douglas framework: after Carroll made a prima facie showing, the burden shifted to IDEMIA to articulate a legitimate reason (poor performance on Trusted Fan). Carroll then had to show pretext.

2. Reasonableness Standard vs. Honest-Belief Rule
IDEMIA invoked the honest-belief rule (it genuinely believed Carroll’s leadership failed). The Sixth Circuit held that rule applies only when an employee attacks the factual basis of the employer’s explanation. Carroll instead attacked the reasonableness of firing him for Trusted Fan’s failure—challenging IDEMIA’s motivation. That attack falls outside honest-belief’s scope.

3. Pretext Analysis
To show pretext by reasonableness, Carroll needed evidence that no sensible employer would have fired him for the Trusted Fan issues. IDEMIA presented contemporaneous critiques by CEO Casey and a business-model review confirming fundamental flaws (no viable revenue estimates, no project plan, immaturity of digital strategy). Carroll only pointed to the slow technology unit, inflated projections, and good past performance—insufficient to create a genuine dispute.

4. Age-Discrimination Claim
The court required but-for causation under the ADEA. Alleged comments (“why work so hard at your age,” “not putting you out to pasture”) were isolated, ambiguous, and unconnected to the termination decision.

5. Contract Claim
Carroll’s contract disallowed severance when terminated for performance or misconduct. IDEMIA’s undisputed evidence proved a performance-based firing, foreclosing breach.

Impact

Management-Level Decisions: Reinforces deference to employer judgments about executive performance, especially when supported by contemporaneous evaluations and expert reviews.
Pretext Proof: Clarifies that challenging the reasonableness of a termination is a distinct pretext theory, not subject to the honest-belief rule’s constraints.
Stray Remarks: Isolated comments about health or age, unlinked to the adverse action, are insufficient to avoid summary judgment.
Contractual Severance: Employers may enforce “for cause” clauses where performance issues are documented and undisputed.

Complex Concepts Simplified

Prima Facie Case (McDonnell Douglas): The minimum showing (disability/age, qualification, adverse action, knowledge of disability/age, replacement or disparate treatment).
Honest-Belief Rule: If an employer honestly and reasonably believed its stated reason for termination, the employee cannot show pretext merely by proving the belief was wrong—but only when the employee is challenging the factual basis of the reason.
Reasonableness Standard: To prove pretext by attacking motivation, an employee must show that no reasonable employer would have relied on the stated reason.
But-For Causation (ADEA): Age must be the actual cause of the adverse decision, not just a motivating factor.
Summary Judgment: Grants judgment without trial when there is no genuine dispute of material fact and one party is entitled to judgment as a matter of law.

Conclusion

Charles Carroll v. IDEMIA reaffirms that performance-based terminations of senior executives will withstand ADA and ADEA attacks absent compelling evidence that the employer’s decision was unreasonable or motivated by discrimination. The decision sharpens the boundary between attacking the factual basis of an employer’s belief and attacking the reasonableness of the decision itself. It also underscores that stray comments about health or age, without a clear nexus to the adverse action, cannot sustain discrimination claims. Finally, it confirms that “for cause” severance provisions are enforceable when performance defects are indisputably documented.