Employer Did Not Retaliate Against Employee For Filing Sexual Harassment Complaint
An employer's adverse actions of placing the
employee on a performance improvement plan (PIP) and her later termination were
not caused by the employee's complaint of sexual harassment, as required for her
Title VII retaliation claim. The employer had already made the decision to place
the employee on a PIP before she made her complaint, so the employer was not
aware of her protected activity. The six-month lapse between her complaint and
her termination could not by itself establish retaliation. Moreover, the
employee had only bare suppositions and unsupported allegations as
circumstantial evidence for causation.
Smith v. Quintiles Transnational Corp.