Equal Employment Opportunity Commission v. Francis W. Parker School

concluding that, under Hazen Paper’s reasoning, no disparate impact theory can exist under ADEA | “decisions based on criteria which merely tend to affect workers over the age of forty more adversely than workers under forty are not prohibited” | statements made in press release attacking use of funds from recent tax levy benefiting Drake Center and conversion of 75% of hospital beds to private status did not touch matters of public concern | statements made in press release attacking use of funds from recent tax levy benefiting Drake Center and conversion of 75% of hospital beds to private status did not touch matters of public concern