Springfield Power Co. lost a major electricity customer when General Motors closed several auto factories in Springfield’s service area. Because of the loss of business, Springfield decided to reduce its workforce. Managers were instructed to rate their workers on the factors of “performance, flexibility, and critical skills.” Using those discretionary ratings, combined with points for years of service, the company then decided which workers would be laid off. Of the thirty-one workers who were laid off, thirty of them were over the age of forty. Several of the employees who were laid off file suit against Springfield under the ADEA. Can the workers establish a prima facie case of age discrimination?

What defense can the employer raise here? See Meacham v. Knolls Atomic Power Lab. [128 S.Ct.

2395 (2008)].