Age Discrimination Claims Will Continue to Be Analyzed Using a ‘But-For’ Standard

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The U.S. 6th Circuit Court of Appeals (whose rulings apply to all Ohio employers) affirmed summary judgment (dismissal without a trial) in favor of an employer and held claims filed under the Age Discrimination in Employment Act (ADEA) must continue to be judged using a “but-for” standard.

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Melanie Pelcha was employed as a bank teller by Watch Hill Bank. A new supervisor instituted a policy that her direct reports must submit written requests for time off approximately one month in advance.

Pelcha sought to take time off from work, but she

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