Burlington N. & Santa Fe Ry. Co. v. White

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In Brief

 

Title VII makes unlawful any act of retaliation by an employer that well might dissuade a reasonable employee from making or supporting a charge of discrimination pursuant to Title VII.

What Happened in Court

Sheila White was the only female employee in her department. She complained about sexual harassment and discrimination. For her complaints, she was suspended but ultimately prevailed in challenging the suspension before the EEOC. She later amended her complaint to include a claim of retaliation, citing to the suspension as the adverse action at issue. After trial before the District Court and an appeal to the Sixth Circuit, the Supreme Court ultimately took the case to determine the appropriate standard for determining whether an adverse action had occurred. In an important and often cited opinion, the Supreme Court held that Title VII makes unlawful any act of retaliation by an employer that well might dissuade a reasonable employee from making or supporting a charge of discrimination pursuant to the act.