Case Explained: ROBERT R. RICHARDSON v. NORTHWESTERN MEMORIAL HEALTHCARE and CENTRAL DUPAGE PHYSICIAN GROUP, d/b/a Northwestern Medicine Regional Medical Group

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-07-29 The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Northwestern Memorial Healthcare and Central DuPage Physician Group in an age discrimination lawsuit brought by Dr. Robert Richardson under the Age Discrimination in Employment Act (ADEA). The court held that Dr. Richardson failed to produce sufficient evidence to create a genuine dispute of material fact regarding whether his age was the “but-for” cause of his termination, as required by *Gross v. FBL Financial Services, Inc.* The court applied the standard that an ADEA plaintiff must prove age played a determinative role in the employer’s decision-making process. While acknowledging that RMG managers made comments suggesting Dr. Richardson’s age and health risks were factors in keeping him on remote work during the pandemic, the court found these statements did not connect to the subsequent termination decision. The court determined that the temporal gap between the COVID-related remarks and the termination notice was insufficient to establish pretext without additional corroborating evidence. Furthermore, the court accepted RMG’s legitimate, nondiscriminatory business justification for the firing: a shift toward an APP-intensive staffing model driven by productivity metrics (RVUs) and cost considerations, specifically that Dr. Richardson’s role and compensation structure were inconsistent with this new operational goal. The court noted that even if the decision-makers were mistaken about Dr. Richardson’s capabilities, such error does not constitute pretext absent proof of dishonesty. As a result, the judgment for the defendants stands, and Dr. Richardson’s claim is dismissed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.