Testa v. CareFusion
Stephen Testa, proceeding pro se, sued CareFusion alleging age discrimination under the ADEA and New York Labor Law. Testa, hired at 52 and terminated at 53, claimed his poor job performance was a pretext for age-based termination, citing a younger replacement and supervisor remarks about his "era" and "younger sales manager" skills. CareFusion moved for summary judgment, arguing Testa's termination was solely due to documented poor performance, including failure to meet sales objectives and Performance Improvement Plan requirements. The court found Testa's performance issues undisputed and ruled that the supervisor's alleged stray remarks, made months before termination, were insufficient to establish discriminatory intent. Consequently, the court granted summary judgment to CareFusion on the ADEA claim and dismissed the state law claims without prejudice, concluding Testa was fired for poor performance, not age.