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Keywords

damagesdiscriminationharassmentrespondent
discriminationharassmentrespondent

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University of Texas Sw. Medical Center v. Nassar

Facts

Petitioner, the University of Texas Southwestern Medical Center, employed respondent, a medical doctor of Middle Eastern descent, who alleged that he faced discrimination and harassment from his superior, Dr. Beth Levine, based on his religion and ethnicity. After resigning from his teaching position due to this alleged harassment, he claimed retaliation when the University intervened to prevent him from being hired at a hospital. The jury found in favor of the respondent on both discrimination and retaliation claims, awarding him significant damages.

Petitioner, the University of Texas Southwestern Medical Center, employed respondent, a medical doctor of Middle Eastern descent, who alleged that he faced discrimination and harassment from his superior, Dr. Beth Levine, based on his religion and ethnicity.

Issue

Whether the standard of causation for Title VII retaliation claims requires but-for causation or if a lessened standard applies.

Whether the standard of causation for Title VII retaliation claims requires but-for causation or if a lessened standard applies.

Rule

Title VII retaliation claims must be proved according to traditional principles of but-for causation, meaning that the unlawful retaliation would not have occurred in the absence of the alleged wrongful action or actions of the employer.

Title VII retaliation claims must be proved according to traditional principles of but-for causation.

Analysis

The court determined that the Fifth Circuit's application of a lessened causation standard for retaliation claims was incorrect. It emphasized that the traditional but-for causation standard must apply, requiring proof that the adverse employment action would not have occurred without the employer's retaliatory motive.

The court determined that the Fifth Circuit's application of a lessened causation standard for retaliation claims was incorrect.

Conclusion

The Supreme Court vacated the Fifth Circuit's decision and remanded the case for further proceedings, affirming that but-for causation is required for Title VII retaliation claims.

The Supreme Court vacated the Fifth Circuit's decision and remanded the case for further proceedings.

Who won?

The University of Texas Southwestern Medical Center prevailed in part, as the Supreme Court vacated the Fifth Circuit's ruling on the retaliation claim, establishing that but-for causation is necessary.

The University of Texas Southwestern Medical Center prevailed in part, as the Supreme Court vacated the Fifth Circuit's ruling on the retaliation claim.

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