Last week, the Supreme Court issued a 5-4 ruling that will make it more difficult for some older workers to succeed in proving age discrimination by their employers. In Gross v. FBL Financial Services, Inc., the Court held that employees suing under the Age Discrimination in Employment Act (ADEA), unlike those suing for race or sex discrimination under Title VII, cannot make use of the "mixed-motive" theory that makes it easier to prove discrimination when there is evidence of both legitimate and illegitimate motives for an adverse employment action....