In Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. –, No. 05-259 (June 22, 2006), the U.S. Supreme Court held that the anti-retaliation provision of Title VII of the Civil Rights Act of 1964, 42 U.S.C. � 2000e-3(a) is broader than Title VII’s anti-discrimination provision, resolving differences among the circuit courts of appeal over what constitutes actionable retaliation.
Specifically, the Court addressed:
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