Amit Sinha v. Bradley University, 995 F.3d 568

Amit Sinha, a finance professor at Bradley University, was department chair until removed on March 22, 2017; he was denied promotion in 2016 and again in 2017, then promoted in 2018.
Dean Darrell Radson (accused by Sinha of age bias) recommended personnel changes; Provost Walter Zakahi requested a Title IX investigation and removed Sinha as chair citing a toxic, dysfunctional department.
Sinha alleges retaliation under the ADEA for opposing Radson’s purported age-discriminatory requests (refusing to make older faculty positions undesirable).
Sinha filed EEOC/IDHR charges: July 31, 2017 (challenging removal as chair) and February 28, 2018 (challenging denial of the Sept. 22, 2017 promotion application).
The district court granted summary judgment for Bradley: (1) removal-as-chair claim failed because Radson did not proximately cause Zakahi’s independent decision (cat’s paw proximate-cause failure); (2) denial-of-promotion claim was time‑barred because the complaint relied on the 2016 denial and no timely EEOC charge was filed.
The Seventh Circuit affirmed: affirmed rejection of cat’s paw causation for the removal claim and affirmed that the promotion claim was untimely and not excused as a scrivener’s error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Removal as department chair — cat's paw proximate cause	Radson (biased subordinate) created a false narrative and influenced Zakahi to remove Sinha; Radson's animus caused the adverse action	Zakahi conducted independent investigations (faculty grievance and Title IX) and independently decided to remove Sinha for department dysfunction	Court: No proximate causation; Zakahi’s independent decision breaks cat’s paw chain; summary judgment for Bradley affirmed
Denial of promotion — timeliness of EEOC charge	The complaint’s reference to the 2016 denial was a scrivener’s error; the claim is actually based on the 2017 denial (timely charged Feb. 28, 2018)	Complaint and discovery repeatedly identified the 2016 denial; plaintiff received unequivocal notice in March 2017 and failed to file within 300 days	Court: Claim time‑barred as pled; not excused as a scrivener’s error; summary judgment for Bradley affirmed

Staub v. Proctor Hosp., 562 U.S. 411 (2011) (cat’s-paw proximate-causation framework; biased subordinate can cause employer liability unless decisionmaker’s independent investigation breaks the chain)
Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009) (ADEA requires age to be the but‑for cause)
Wrolstad v. Cuna Mut. Ins. Soc’y, 911 F.3d 450 (7th Cir. 2018) (timing: limitations begin when employee receives unequivocal notice of a final decision)
Nichols v. Michigan City Plant Planning Dep’t, 755 F.3d 594 (7th Cir. 2014) (cat’s-paw requires both subordinate animus and proximate causation)
Skiba v. Illinois Cent. R.R. Co., 884 F.3d 708 (7th Cir. 2018) (summary-judgment standard in ADEA adverse-action cases)
Igasaki v. Illinois Dep’t of Fin. & Prof. Reg., 988 F.3d 948 (7th Cir. 2021) (standard of review for summary judgment in employment discrimination appeals)