Hodge v. New York College of Podiatric Medicine
Dr. William Hodge, a 67-year-old professor employed by St. John's College since 1973, faced non-renewal of his contract in February 1993, with the defendant citing his high salary. Despite a history of excellent performance reviews and a faculty committee ruling that there was insufficient cause for non-renewal, plaintiff entered into an agreement in April 1994. This agreement stipulated his continued employment until June 30, 1995, in exchange for withdrawing his age discrimination charge with the Equal Employment Opportunity Commission (EEOC). After his contract was not renewed in 1995, Dr. Hodge filed a claim under the Age Discrimination in Employment Act (ADEA) in August 1995. The court granted the defendant's motion to dismiss, deeming the claim time-barred. The court ruled that Dr. Hodge's claim was filed more than 90 days after the termination of the EEOC proceedings, and that by accepting the benefits of the 1994 agreement, he had ratified the contract, making the withdrawal of his EEOC charge effective despite any potential non-compliance with the Older Workers’ Benefits Protection Act (OWBPA) requirements.