In Geiger v. Tower Automotive, the Sixth Circuit Court of Appeals (Cincinnati) held that employees who have been terminated as part of a work force reduction must meet a higher standard of proof to establish a valid claim for age discrimination. The court held that if an employee is terminated as a part of a reduction in force, the employee must provide "additional direct, circumstantial, or statistical evidence tending to indicate that the employer singled out the plaintiff for discharge for impermissible reasons." As the employee was unable to provide such additional evidence, his case was dismissed. This case creates a substantial hurdle for age discrimination claimants who have been terminated in conjunction with a reduction in force.