William Richter v. Duquesne University of the Holy Spirit

CourtCourt of Appeals for the Third Circuit
DecidedJanuary 27, 2026
Docket24-3132
StatusUnpublished

This text of William Richter v. Duquesne University of the Holy Spirit (William Richter v. Duquesne University of the Holy Spirit) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William Richter v. Duquesne University of the Holy Spirit, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ________________

No. 24-3132

________________

WILLIAM RICHTER, Appellant

v.

DUQUESNE UNIVERSITY OF THE HOLY SPIRIT; JAMES MILLER _____________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. Civil No. 2:23-cv-00550) District Judge: Honorable Christy Criswell Wiegand ________________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) on October 23, 2025

Before: PORTER, FREEMAN, and CHUNG, Circuit Judges.

(Filed: January 27, 2026)

OPINION* ________________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. PORTER, Circuit Judge.

William Richter sued his former employer, Duquesne University, for age

discrimination and retaliation under federal and Pennsylvania law. The District Court

granted summary judgment for Duquesne. Because we conclude that Richter has not

established a prima facie case for either age discrimination or retaliation, we will affirm

the District Court’s grant of summary judgment.

I

A

William Richter was a gift officer in the advancement office at Duquesne

University, a private Catholic college, from 2015 until he was terminated on August 17,

2022. The university hired him when he was 55 years old, promoted him twice (at 60 and

61 years old) then fired him at 62 years old.

Since July 2021, James Miller (age 57 in August 2022) led Duquesne’s

advancement office. In early 2022, Miller restructured the advancement office at the

request of the university president. The restructuring included reallocating gift officers’

portfolios. At least one donor in Richter’s 431-donor portfolio was transferred to another

portfolio managed by gift officer Melissa Krebs, who was younger than Richter. In his

deposition, Richter admitted that 431 donors was not a reasonable number for a gift

officer to handle.

When Krebs secured a $50,000 commitment from the transferred donor, Richter

accused her of stealing his donor and lying to the donor. In March 2022, Richter

2 complained to Miller and then filed a complaint with the university human resources

department. That complaint did not reference age. Richter filed a second human resources

complaint that he emailed to two human resources employees. Although the second

complaint form did not mention age, the accompanying email said that Richter planned to

file an age discrimination complaint if he did not receive credit for the $50,000 gift. The

university’s investigative report resulting from Richter’s complaints does not mention age

discrimination. Richter never heard Miller make any comments related to age, and Miller

says that, although Richter’s second complaint was shared with him, he never saw the

email referencing age discrimination.

Around the time Richter filed his human resources complaints, he solicited a

seven-figure, deferred, revocable gift in exchange for an unapproved agreement that

granted the donor perpetual naming rights to a university center. Richter’s solicitation

violated university policies that required this type of gift to be irrevocable and approved

by the university president. Separate from this incident, Richter had several other

performance and conduct issues: he sent a sexually-explicit text message to the provost;

he jeopardized a donor relationship by failing to keep a dean informed; he failed to

resolve a significant mathematical error that resulted in a monetary shortage; and he

communicated callously with coworkers. According to the university, Richter’s policy

violation regarding naming rights was the last straw that led Miller to terminate Richter in

August 2022.

B

In March 2023, Richter filed suit against the university and Miller, alleging age

3 discrimination and retaliation in violation of the Age Discrimination in Employment Act

(“ADEA”) and the Pennsylvania Human Relations Act (“PHRA”). The District Court

granted summary judgment for the university on October 15, 2024, and held that Richter

had not made a prima facie case for either claim. Richter timely appealed.

II

The District Court had jurisdiction under 28 U.S.C. §§ 1331, 1367(a). We have

jurisdiction under 28 U.S.C. § 1291.

This Court reviews the District Court’s grant of summary judgment de novo,

applying the same standards and presumptions as the District Court. Campbell v. Pa. Sch.

Bds. Ass’n, 972 F.3d 213, 225 (3d Cir. 2020). We will affirm if “there is no genuine

dispute of material fact and [ ] the moving party is entitled to judgment as a matter of

law.” Qin v. Vertex, Inc., 100 F.4th 458, 469 (3d Cir. 2024).

III

We analyze age discrimination and retaliation claims premised on circumstantial

evidence under the three-step burden-shifting framework articulated in McDonnell

Douglas Corp. v. Green, 411 U.S. 792 (1973).1 Marra v. Phila. Hous. Auth., 497 F.3d

286, 300 (3d Cir. 2007). First, “the employee bears the initial burden of establishing a

prima facie case” of age discrimination or retaliation. Id. at 300; see also Anderson v.

Consol. Rail Corp., 297 F.3d 242, 249 (3d Cir. 2002). Second, if the employee clears step

1 We analyze claims brought under the Age Discrimination in Employment Act and the Pennsylvania Human Relations Act coextensively. See Daniels v. Sch. Dist. of Philadelphia, 776 F.3d 181, 192–93 (3d Cir. 2015).

4 one, “the burden of production shifts to the employer to articulate some legitimate, non-

retaliatory reason for the adverse employment action.” Marra, 497 F.3d at 300. Third, if

the employer clears step two, the employee must show that the employer’s explanation

was a pretext for discrimination or retaliation. Id. The District Court held that Richter’s

claims fail at step one. We agree.

Under the ADEA, it is unlawful for an employer to “discharge any

individual . . . because of such individual’s age.” 29 U.S.C. § 623(a)(1). To establish

a prima facie case of age discrimination, a plaintiff must establish that he (1) was at least

forty years old, (2) was qualified for the position, (3) suffered an adverse employment

action, and (4) suffered the adverse employment action under circumstances that support

an inference of discrimination. Anderson, 297 F.3d at 249 (citing Showalter v. Univ. of

Pittsburgh Med. Ctr., 190 F.3d 231, 235 (3d Cir. 1999)).

The plaintiff can satisfy the fourth element by demonstrating that “the employer

retained someone similarly situated to him who was sufficiently younger.” Id. at 250.

Two employees are similarly situated only if they share in relevant aspects of

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Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Thomas v. Town of Hammonton
351 F.3d 108 (Third Circuit, 2003)
Marra v. Philadelphia Housing Authority
497 F.3d 286 (Third Circuit, 2007)
Dorothy Daniels v. Philadelphia School District
776 F.3d 181 (Third Circuit, 2015)
Simon Campbell v. Pennsylvania School Boards
972 F.3d 213 (Third Circuit, 2020)
Qing Qin v. Vertex Inc
100 F.4th 458 (Third Circuit, 2024)

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