The United States Supreme Court recently issued an opinion in Gross v. FBL Financial Services, Inc. that greatly enhances the standard of proof plaintiffs must satisfy when asserting age discrimination actions under the Age Discrimination in Employment Act (“ADEA”). In Gross, the court held that, unlike in Title VII discrimination cases, a plaintiff asserting an ADEA claim must prove his or her protected characteristic was the determinative factor for the employer’s adverse action (as opposed to just one factor among many under a “mixed-motives” theory). For this reason, plaintiffs asserting discrimination claims under the ADEA now bear a much greater burden than do those asserting Title VII discrimination claims.