University of Texas Southwestern Medical Center v Nassar
June 24, 2013
Case #: 12-484
Kennedy, J., delivered the opinion of the Court, in which Roberts, C. J., and Scalia, Thomas, and Alito, JJ., joined. Ginsburg, J., filed a dissenting opinion, in which Breyer, Sotomayor, and Kagan, JJ., joined.
Full Text Opinion: http://www.supremecourt.gov/opinions/12pdf/12-484_o759.pdf
Employment Law: Title VII retaliation claims must be proved according to traditional principles of but-for causation.
Respondent worked for both the Petitioner, and Parkland Hospital (Hospital). Respondent wrote a letter stating that he was being harassed because of his ethnicity by his supervisor. Respondent resigned from working with Petitioner, but continued his employment at the Hospital. Petitioner protested the continued employment and the Hospital withdrew the employment offer.
Respondent first filed suit in the United States District Court of Northern Texas and subsequently appealed to the Court of Appeals for the Fifth Circuit. The lower court found for Respondent and held that the retaliation was a motivating factor for the withdrawal of the employment offer. The Supreme Court granted Certiorari to determine what the standard of proof is required for retaliation claims in violation of Title VII. The Supreme Court vacated, remanded and held that the proper standard is a stricter "but for" causation standard rather than a motivating factor standard.