United States Fourth Circuit

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Foster v. Univ. of Maryland-Eastern Shore, 14-1073

In a case dealing with the effect of the Supreme Court's decision in University of Texas Southwestern Medical Center v. Nassar, 133 S. Ct. 2517 (2013), on what Title VII retaliation plaintiffs must show to survive a motion for summary judgment, the district court's grant of summary judgment is reversed in part where: 1) the Nassar Court was silent as to the application of but-for causation in McDonnell Douglas pretext cases, and 2) Nassar did not alter the McDonnell Douglas analysis for retaliation claims.

Appellate Information

  • Decided 05/22/2015
  • Published 05/22/2015

Judges

  • FLOYD

Court

  • United States Fourth Circuit

Counsel