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Scope of Retaliation Claims Extended

Author: Elizabeth Smith

In Burlington Northern & Santa Fe Railway Co. v. White, +548 U.S. 53 (2006), the United States Supreme Court addressed whether an employer violated the anti-retaliation provisions of Title VII of the Civil Rights Act of 1964 when it reassigned an employee to less desirable job duties and later suspended her after she filed a discrimination claim. In doing so, the Supreme Court dramatically expanded the scope of the anti-retaliation provisions of Title VII when it ruled that such provisions extend to any challenged actions which might dissuade a reasonable worker from making or supporting a charge or discrimination and are not limited to employment-related actions occurring in the workplace.