A seventy-three-year-old physician alleges that he was terminated from his leadership role at a family medicine residency program due to his age and without proper notice, according to a recent federal court filing. The complaint was filed by Dr. Robert Pallay on April 3, 2026, in the United States District Court for the Southern District of Georgia against Savannah Primary Care Associates, LLC doing business as Memorial Health — Family Medicine.
Dr. Pallay’s lawsuit asserts claims under the Age Discrimination in Employment Act (ADEA) as well as Georgia state law for breach of contract and litigation expenses. According to the filing, Dr. Pallay had been employed since 2018 by Savannah Primary Care after it acquired Memorial Health Inc., where he had worked since 2007 as both a family physician and Program Director for the Family Medicine Residency Program at Memorial Health University Medical Center.
The complaint states that Dr. Pallay signed an employment agreement with Savannah Primary Care effective March 1, 2022. This agreement allowed either party to terminate employment ‘without cause’ provided ninety days’ written notice was given. Dr. Pallay claims he consistently received positive evaluations from managers and colleagues and led successful programs benefiting underserved communities.
According to the document, issues arose near the end of Dr. Pallay’s tenure when Jake Stone, Senior Vice President for the South Atlantic Division, allegedly made comments about Dr. Pallay’s age and potential retirement plans despite no indication from Dr. Pallay that he intended to retire soon. On October 3, 2023, Dr. Pallay was called into a meeting with Vice President of Operations Robert A. Faile and Market Director Carla Norman where he was presented with a Termination and Release Agreement (TRA). The TRA stated his employment would end immediately that day and required him to waive his right to ninety days’ notice or pay-out.
The complaint alleges that Mr. Faile threatened to issue a letter impugning Dr. Pallay’s reputation if he did not sign the TRA immediately, leading Dr. Pallay to sign out of fear and under duress. It further contends that the TRA did not include any notices required by the Older Worker’s Benefit Protection Act (OWBPA), such as reference to ADEA rights or advisement to consult an attorney.
Dr. Pallay revoked his execution of the TRA one week later on October 10, 2023, arguing that it lacked consideration and imposed one-sided obligations solely on him while providing no benefit in return from Savannah Primary Care Associates. He also asserts that replacing him with someone more than twenty years younger supports his claim of age discrimination.
The lawsuit outlines three counts: discriminatory termination in violation of ADEA; breach of contract under Georgia law due to failure to provide ninety days’ notice; and liability for litigation expenses due to alleged bad faith conduct by Savannah Primary Care Associates.
In terms of relief sought from the court, Dr. Pallay requests declaratory judgment recognizing violations of ADEA; lost wages and benefits; liquidated damages for willful violations; compensation equal to what would have been earned during the ninety-day notice period; interest; reinstatement or front pay; costs including attorneys’ fees; expert fees; and any other relief deemed appropriate by the court.
The plaintiff is represented by attorneys James Radford (Georgia Bar No. 108007) and Zachary Panter (Georgia Bar No. 822012) of Radford Scott LLP based in Decatur, Georgia. The case is identified as Civil Action No.: 4:26-cv-00085-RSB-CLR.
Source: 426cv00085_Robert_Pallay_v_Savannah_Primary_Complaint_Southern_District_of_Georgia.pdf
