On August 7, 2023, the U.S. Court of Appeals for the Second Circuit in Carr v. New York City Transit Authority (No. 22-792-cv, 2023 WL 5005655) (“Carr”) revisited and clarified the appropriate legal standard for analyzing claims of retaliation under Title VII of the Civil Rights Act of 1964. The Second Circuit held that employees have broader protections under Title VII’s anti-retaliation clause than they do under the anti-discrimination clause of the same statute.