Plaintiff Terry Bechel sued defendant Charter Communications, LLC in the United States District Court for the Eastern District of Missouri, Eastern Division, raising claims of age discrimination under the Missouri Human Rights Act (MHRA) and the federal Age Discrimination in Employment Act (ADEA). Charter Communications, LLC moved to dismiss Bechel’s claims under Rule 12(b)(6).
Factual Overview
Terry Bechel worked for Charter Communications, LLC from 2004 to 2022, starting as a maintenance technician and eventually being promoted to Maintenance Supervisor and Field Operations Manager. Bechel consistently received positive performance reviews, pay raises, and bonuses throughout his employment. In February 2022, Bechel was transferred to manage a smaller, underperforming territory, which he was concerned might negatively impact his compensation. Soon after the transfer, Bechel was reprimanded for his handling of an employee discipline issue in his old territory. On March 29, 2022, at the age of 52, Bechel was terminated, with his supervisor citing the employee discipline issue as the reason. However, Bechel alleges that the reprimand and transfer were a pretext for unlawful age discrimination.
Bechel initially sued Charter and his supervisor, Robert Burton, in state court for violations of the MHRA and ADEA. The case was removed to the United States District Court for the Eastern District of Missouri, and Bechel dismissed the claims against Burton.
Legal Analysis
Age Discrimination Claims: The court noted that discrimination claims under the MHRA are considered under the same analysis as claims under the ADEA. To succeed on his claims, Bechel must show that he was at least 40 years old, qualified for the position, suffered an adverse employment action, and was rejected for someone sufficiently younger to permit the inference of age discrimination. While Bechel need not establish a prima facie case at this stage, he must offer enough factual allegations to raise a right to relief above a speculative level.
The court found that Bechel failed to state a claim for age discrimination, as he did not plead facts that would enable the court to infer that his age was a factor in his transfer, reprimand, and termination. Bechel’s allegations were conclusory and did not raise a right to relief above the speculative level.
Conclusion
The United States District Court for the Eastern District of Missouri granted Charter Communications, LLC’s motion to dismiss Bechel’s age discrimination claims under the MHRA and ADEA without prejudice, allowing Bechel to file a motion for leave to file an amended complaint by July 12, 2024.
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