Robert Sloat v. Hewlett-Packard Enter. Co., 18 F.4th 204

Sloat was hired by Hewlett‑Packard in 2011 (age 54), received consistently strong reviews and 30% bonuses through 2015, and created a global training program called “Ropes to the Ground.”
Promoted to director in June 2016; his position was transferred to manager Steven Hagler in November 2016 (Sloat then age 60).
After the transfer Hagler marginalized Sloat: gave a low bonus/no raise, mocked him in meetings (called him "Uncle Ron" and said he had "old skills"), repeatedly asked “When are you going to retire?”, stripped Sloat of responsibilities (reassigning Ropes to Sandy Connor), and gave a mid‑year “Stalled” rating.
Hagler proposed a one‑person workforce reduction and conveyed negative information about Sloat to others; HR spreadsheets designated Sloat as a “plan for exit.” Flynn (another manager) shortly after spoke with Hagler and put Sloat on the slate for termination; Flynn effectuated the discharge.
Sloat sued under the ADEA and Tennessee Human Rights Act for age discrimination and retaliation; the district court granted summary judgment for Hewlett‑Packard, and the Sixth Circuit reversed and remanded for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Age discrimination (ADEA/Tenn. Act)	Hagler exhibited age bias (retirement questions, demeaning remarks, demotion/stripping duties, bad review) and caused Flynn to fire Sloat (cat’s‑paw/proximate cause), so age was a but‑for cause.	Flynn was the actual decisionmaker; the stated reason (redundant duties / others could absorb work) was legitimate and nondiscriminatory.	A reasonable jury could find Hagler was the relevant decisionmaker and that his age bias proximately and but‑for caused termination; summary judgment reversed.
Retaliation (after complaint)	After Sloat complained to HR and confronted Hagler, Hagler reacted angrily, avoided him, stripped duties, sought a one‑person WFR, and pushed exit documents—supporting retaliatory motive and pretext.	Same nondiscriminatory redundancy explanation; no sufficient causal link between complaint and firing.	The evidence permits a jury to find retaliatory motive and pretext; summary judgment improper.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden‑shifting framework for discrimination claims)
Staub v. Proctor Hosp., 562 U.S. 411 (2011) (employer liable for biased intermediate actor who proximately causes adverse action)
Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009) (but‑for causation standard in ADEA cases)
Pelcha v. MW Bancorp, Inc., 988 F.3d 318 (6th Cir. 2021) (discussion of determinative influence / causation standard)
Geiger v. Tower Auto., 579 F.3d 614 (6th Cir. 2009) (WFR termination: must show employer singled out plaintiff)
Imwalle v. Reliance Med. Prods., Inc., 515 F.3d 531 (6th Cir. 2008) (retaliation analyzed under McDonnell Douglas framework)
Mys v. Mich. Dept. of State Police, 886 F.3d 591 (6th Cir. 2018) (vicarious liability where supervisor causes adverse action)
Niswander v. Cincinnati Ins. Co., 529 F.3d 714 (6th Cir. 2008) (summary judgment standard)