The U.S. Court of Appeals for the Third Circuit affirmed a lower court's dismissal of an age discrimination lawsuit against Duquesne University, ruling that former employee William Richter failed to prove his claims under federal and state employment law.
In the non-precedential opinion filed Jan. 27, 2026, a three-judge panel consisting of Circuit Judges Porter, Freeman, and Chung unanimously upheld the Western District of Pennsylvania's grant of summary judgment in favor of the private Catholic university and James Miller, who led the school's advancement office.
Richter, who worked as a gift officer in Duquesne's advancement office from 2015 until his termination on Aug. 17, 2022, alleged age discrimination and retaliation under both federal law and Pennsylvania employment statutes. The university hired Richter when he was 55 years old and promoted him twice—at ages 60 and 61—before terminating his employment when he was 62.
Writing for the panel, Circuit Judge Porter concluded that Richter had not established a prima facie case for either age discrimination or retaliation claims. The court's analysis focused on whether Richter could demonstrate the essential elements required under employment discrimination law to survive summary judgment.
The case originated in the advancement office restructuring that began in early 2022 under Miller's leadership. Miller, who was 57 years old at the time of Richter's termination in August 2022, had assumed control of Duquesne's advancement office in July 2021. The restructuring occurred as Miller sought to reorganize the department's operations and personnel.
Richter filed his initial complaint in federal district court in 2023, case number 2:23-cv-00550, before District Judge Christy Criswell Wiegand. The district court granted summary judgment in favor of Duquesne University and Miller, prompting Richter's appeal to the Third Circuit.
Under federal age discrimination law, plaintiffs must establish a prima facie case by showing they were in a protected age group, qualified for the position, suffered an adverse employment action, and that the action occurred under circumstances giving rise to an inference of discrimination. The Age Discrimination in Employment Act protects workers who are 40 years old and older.
For retaliation claims, employees must demonstrate they engaged in protected activity, suffered an adverse employment action, and that a causal connection exists between the protected activity and the adverse action. Courts analyze whether the timing, sequence of events, and other circumstances support an inference that retaliation motivated the employer's decision.
The Third Circuit's decision represents a complete victory for Duquesne University in defending against Richter's employment claims. The court's ruling that Richter failed to establish even the basic elements of his discrimination and retaliation claims suggests the evidence did not support his allegations of age-based bias or retaliatory conduct.
Private universities like Duquesne face employment discrimination lawsuits with increasing frequency as the higher education workforce ages and institutions undergo administrative restructuring. The case highlights the challenges employees face in proving discrimination claims when employers can articulate legitimate, non-discriminatory reasons for personnel decisions.
The opinion was submitted under Third Circuit Local Appellate Rule 34.1(a) on Oct. 23, 2025, following oral arguments. This procedural designation indicates the court determined the case appropriate for resolution without full briefing and oral argument, typically reserved for cases involving well-settled legal principles.
As a non-precedential opinion, the Third Circuit's decision does not establish binding precedent for future cases but reflects the court's application of established employment discrimination law to Richter's specific factual circumstances. The ruling provides guidance on the evidentiary standards required to survive summary judgment in age discrimination cases.
The case also involved Pennsylvania state law employment discrimination claims, which generally parallel federal standards under the Age Discrimination in Employment Act. Pennsylvania's Human Relations Act provides additional protections for workers but requires similar proof elements for successful discrimination claims.
Duquesne University, founded in 1878 as a private Catholic research university in Pittsburgh, employs hundreds of faculty and staff members across its academic and administrative operations. The advancement office, where Richter worked, handles fundraising and donor relations activities critical to the university's financial sustainability.
The affirmance concludes Richter's federal court challenge to his termination, though the decision does not preclude potential state court proceedings or administrative remedies. Employment discrimination cases often involve complex factual disputes about workplace dynamics, performance evaluations, and the true motivations behind personnel decisions.
For employers, the decision reinforces the importance of documenting legitimate business reasons for employment actions and maintaining consistent application of workplace policies. For employees, the case demonstrates the substantial evidentiary burden required to prove discrimination claims in federal court, particularly at the summary judgment stage where courts view facts in the light most favorable to the non-moving party.