Gross v. FBL Financial Services, Inc., 557 U.S. 167 (2009)
Gross v. FBL Financial Services, Inc.
Whether a plaintiff must prove that age was the 'but-for' cause of an employer's adverse decision to prevail in an ADEA claim.
To succeed in a claim under the ADEA, the plaintiff must prove that age was the 'but-for' cause of the employer’s adverse decision.
The Supreme Court held that in age discrimination cases under the ADEA, the plaintiff must prove that age was the 'but-for' cause of the employer's discriminatory conduct.
Gross v. FBL Financial Services, Inc. is a cornerstone case for understanding the proof requirements in age discrimination lawsuits. By establishing a 'but-for' causation standard under the ADEA, the decision placed a higher burden on plaintiffs, making it more difficult for them to prevail at trial. This case stresses the importance of statutory interpretation and illustrates how slightly differing statutory language can lead to substantial differences in judicial outcomes. Law students should understand this case to grasp how procedural aspects of employment discrimination claims can critically influence a plaintiff’s ability to litigate successful claims.