A federal judge has ruled that a student need only show that their protected activity was a motivating factor in a school’s adverse action against them to establish a retaliation claim under Title IX. 

U.S. District Judge Gene Pratter of the Eastern District of Pennsylvania issued her memorandum in support of a “motivating factor” standard of causation Monday, writing that the U.S. Supreme Court and the U.S. Court of Appeals for the Third Circuit had yet to clearly outline what standard is most appropriate.