Martinez v. UPMC Susquehanna

In Martinez v. UPMC Susquehanna, the plaintiff doctor sued after he was fired without much explanation and replaced by two younger doctors. The District Court dismissed his age-discrimination suit, treating his complaint’s allegation that his replacements were “significantly younger” as a legal conclusion. The 3rd Circuit reversed, ruling that the phrase “significantly younger” was a factual allegation, not a legal one. The 3rd Circuit first noted that, to survive a motion to dismiss, the complaint need only allege enough facts to raise a reasonable expectation that discovery will reveal evidence of each necessary element. The 3rd Circuit then held that the factual allegations in the plaintiff’s complaint — he was over forty years old, qualified for the job, fired and not rehired, and his replacements were not only “significantly younger,” but also less qualified and experienced — made out a prima facie case.