In Meacham v. Knolls Atomic Power Laboratory, the U.S. Supreme Court, analyzing the burden of proof in a disparate impact age discrimination claim under the federal ADEA, placed the onus on employers to prove that reasonable factors other than age ("RFOA") guided selection decisions in a layoff. Knoll laid off 31 employees, and 30 of the 31 affected employees (including plaintiff Meacham) were 40 years old or older. Meacham alleged disparate impact age discrimination and offered expert testimony that the fact so many older employees were laid off could not have occurred by chance. The lower court ruled in Knolls' favor, concluding that Meacham bore the burden of proof to establish that RFOAs did not exists, and he did not meet his burden. Reversing, the Supreme Court held that Knolls, not Meacham, bore the burden of proof to establish the RFOA defense, and sent the case back to the trial court for further proceedings to assess whether employee "flexibility," among other factors, constituted a RFOA. (The court's decision is consistent with existing California case law.)