7th Circuit rejects university prof's age bias claim under 'cat's paw' theory of liability

A Bradley University professor who was removed as a department chair filed an Age Discrimination in Employment Act (ADEA) claim under the "cat's paw" theory of liability (i.e., a supervisor with no discriminatory animus was manipulated by someone who harbors such animus). The 7th Circuit (which covers Illinois, Indiana, and Wisconsin employers) threw out the claim, however, because the ultimate decision maker conducted an independent investigation without relying on the biased supervisor's statements.

Facts

Amit Sinha was an associate professor and chair of the finance and quantitative methods (FQM) department at Bradley University's business college in Peoria, Illinois. Walter Zakahi was the university provost and senior vice president for academic affairs at the time. He had authority to remove Sinha as a department chair.

In 2016, an FQM department faculty member accused Sinha of sex discrimination. A faculty grievance committee and Title IX investigators performed probes and let Zakahi know there was severe dysfunction within the FQM department. But the Title IX investigation didn't reveal any evidence of sex discrimination by Sinha.

To address and mitigate the severe dysfunction in the FQM department, the grievance committee and the Title IX investigators each stated Sinha should be removed as department chair. On March 22, 2017, Zakahi removed him as the department leader.