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Retaliation But For Causation

Epstein Becker & Green

Eleventh Circuit Ruling on Causation Standard a Win for Employers

Epstein Becker & Green on

The U.S. Court of Appeals for the Eleventh Circuit recently weighed in on the circuit-splitting debate over the proper causation standard for Family and Medical Leave Act (“FMLA”) retaliation claims. In a win for employers,...more

Benesch

11th Circ. FMLA Ruling Deepens Divide Over Causation

Benesch on

In a win for employers located in Florida, Georgia and Alabama, the U.S. Court of Appeals for the Eleventh Circuit recently concluded that retaliation claims brought under the Family and Medical Leave Act are subject to a...more

Seyfarth Shaw LLP

Eleventh Circuit Holds FMLA Retaliation Requires “But-for” Showing

Seyfarth Shaw LLP on

Seyfarth Synopsis: The United States Court of Appeals for the Eleventh Circuit affirmed a district court’s decision that “but-for” is the proper causation standard for FMLA retaliation claims addressed within the...more

Proskauer - Law and the Workplace

Eleventh Circuit Deepens Circuit Split Over Causation Standard for FMLA Retaliation Claims

On December 13, 2023, an Eleventh Circuit panel firmly established “but-for” causation as the Circuit’s causation standard for Family and Medical Leave Act (FMLA) retaliation claims. Courts across the nation have adopted...more

Benesch

Eleventh Circuit Endorses Heightened Standard for FMLA Retaliation Claims, Deepening Circuit Divide

Benesch on

In a win for employers, the Eleventh Circuit Court of Appeals issued a decision on December 13, 2023, which formally adopted the “but for” causation standard for retaliation claims brought under the Family Medical Leave Act...more

FordHarrison

The Case of Graham v. Barrier Technologies: Reducing Exposure To Liability in the Midst of a Pandemic

FordHarrison on

Executive Summary: On June 15, 2021, the Southern District of Florida granted summary judgment in favor of employer Barrier Technologies, LLC (“Barrier Technologies” or the “employer”), a manufacturer of radiation protection...more

Jackson Lewis P.C.

Seventh Circuit Upholds High Bar For Plaintiffs Filing Retaliation Claims

Jackson Lewis P.C. on

The Seventh Circuit Court of Appeals recently reaffirmed employers’ rights under Title VII to make merit-based hiring decisions, even when it means rejecting a candidate who recently raised a meritorious claim of...more

Morrison & Foerster LLP - Left Coast Appeals

This Week at the Ninth: Sand Dredgers and the Duty to Defend

This week, we take a look at a decision addressing the proper reading of “because” in federal discrimination statutes, and another addressing a California law precluding insurers from covering defense costs in litigation...more

Jackson Lewis P.C.

EEOC Argues For Broader Causation Standard And Provides A Peek Into The EEOC’s Future Focus

Jackson Lewis P.C. on

Legal precedent, including language from the U.S. Supreme Court, requires federal courts to take a broad view of the “but-for” causation standard for determining unlawful age discrimination in the workplace, Equal Employment...more

Rumberger | Kirk

Fifth DCA Finds Florida’s Private Whistleblower Act Requires Proof of But-For Causation

Rumberger | Kirk on

In a recent decision by the Fifth District Court of Appeal, the court held that the proper causation standard in retaliation claims brought under Florida’s Private Whistleblower Act (“FWA”) is but-for causation. This...more

Dorsey & Whitney LLP

Underwriter Failed to Meet Employer’s Expectations, and thus His FCA Retaliation Burden, at Least in the Eighth Circuit

Dorsey & Whitney LLP on

On Monday, the U.S. Court of Appeals for the Eighth Circuit affirmed the Eastern District of Missouri’s dismissal of appellant’s retaliation claim under the False Claims Act, as well as his state law wrongful discharge claim...more

Parker Poe Adams & Bernstein LLP

U.S. Supreme Court Says Section 1981 Claims Require ‘But For' Causation

Section 1981 of the Civil Rights Act of 1866 prohibits discrimination on the basis of race in the making of contracts, including employment contracts. Section 1981 is often used by employees suing for race discrimination as...more

Dorsey & Whitney LLP

D.C. Circuit Weighs in on the FCA’s Anti-Retaliation Statute

Dorsey & Whitney LLP on

Last month, the D.C. Circuit revived a False Claims Act (“FCA”) retaliatory discrimination claim by a former employee of Howard University contending that she was fired by the University for objecting both internally and...more

Seyfarth Shaw LLP

The Sixth Circuit Shows That Balancing ADA Obligations With Enforcement Of Workplace Rules Is Far From An Exercise In Futility

Seyfarth Shaw LLP on

Seyfarth Synopsis: Employers face a tough challenge in trying to balance their obligations under the ADA with efforts to enforce workplace rules. A recent decision out of the United States Court of Appeals for the Sixth...more

Fisher Phillips

Third Circuit Confirms “But-For” Standard for Retaliation Claims Under the False Claims Act

Fisher Phillips on

Last month, the Third Circuit Court of Appeals held that an employee’s protected activity must be the “but for” cause of an adverse action to support a claim for retaliation under the False Claims Act (“FCA”). The Court...more

Mintz - Employment Viewpoints

Third Circuit Rules that Employer-Friendly “But For” Causation Standard Applies to False Claims Act Retaliation Claims

In the case of DiFiore v. CSL Behring, LLC, the Third Circuit ruled for the first time that the more demanding “but for” causation standard applies to retaliation claims under the False Claims Act (“FCA”), rejecting the lower...more

Cozen O'Connor

I-13 – Policies, Policies, Policies, and Microchips Embedded in Employees

Cozen O'Connor on

Michael Schmidt of Cozen O'Connor addresses recent trends and noteworthy developments on certain employment policies related to political activity, confidential customer information, FMLA retaliation, and maximum leave...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Second Circuit Lowers Bar for Causation in FMLA Retaliation Claims

The U.S. Court of Appeals for the Second Circuit recently ruled that to advance a viable claim for retaliation under the Family and Medical Leave Act (FMLA), an employee need only demonstrate that exercising his or her rights...more

Rumberger | Kirk

FCRA Retaliation Claims Require Proof of But-For Causation According to Fourth DCA

Rumberger | Kirk on

In an en banc decision by the Fourth District Court of Appeal in Palm Beach Cty. Sch. Bd. v. Wright, Case No. 4D16–112, WL 1278072 (Fla. 4th DCA Apr. 5, 2017), the court adopted a new standard on causation for Florida Civil...more

Jackson Lewis P.C.

Employee’s Retaliation and Hostile Work Environment Claims Based on a Rumor Spread in the Workplace Survives Motion for Summary...

Jackson Lewis P.C. on

In Baez v. Anne Fontaine USA, Inc., the United States District Court for the Southern District of New York denied an employer’s motion for summary judgment to dismiss a terminated employee’s retaliation claims under Title...more

Jackson Lewis P.C.

Weighty Issues: Obesity And The But-For Test Under The ADAAA

Jackson Lewis P.C. on

Obesity is still a hot topic both in our health conscious culture and in our courtrooms where we continue to see ADAAA claims based on the notion that an employer fired an employee because the employee was obese. After the...more

Butler Weihmuller Katz Craig LLP

Front Pay & Back Pay: How About No Pay?

In Caterpillar Logistics Services, Inc. v. Amaya, 2016 WL 822020 (Fla. 3d DCA July 13th, 2016), Rudolph Amaya suffered an on-the-job injury to his back and knee while working at Caterpillar’s facility.  Shortly thereafter,...more

Seyfarth Shaw LLP

Still Cookin’ In California Court: Bakery Employer Survives EEOC Motion For Summary Judgment

Seyfarth Shaw LLP on

In what has become an oft-used recipe in the EEOC cookbook of Title VII retaliation litigation, the government has once again utilized the strategy of taking an employer’s deposition and thereafter moving for summary...more

Proskauer - Whistleblower Defense

EEOC Proposes Expansive Enforcement Guidance for Retaliation Claims

For the first time in nearly 20 years, the Equal Employment Opportunity Commission has issued proposed enforcement guidance regarding retaliation claims. According to the EEOC, the revised guidance is necessary in light of...more

Seyfarth Shaw LLP

Causation In Federal Remedial Rights And Alternative Pleading

Seyfarth Shaw LLP on

Several recent Supreme Court decisions have upended causation standards in the statutory alphabet soup of federal remedial rights. It is now clear that “but for” causation governs discrimination claims under the Age...more

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