Burlington Northern & Santa Fe Railway Co. v. White
United States Supreme Court
548 U.S. 53 (2006)
Sheila White (plaintiff), the only woman in her department at Burlington Northern (defendant), complained about her supervisor's sexist comments, leading to his 10-day suspension; afterward, White was reassigned away from operating the forklift, one of her more desirable duties, based on coworker complaints that a more senior man should have that job, and was later suspended without pay for alleged insubordination, though internal grievance proceedings found she hadn't been insubordinate and she was reinstated with back pay. White sued under Title VII's anti-retaliation provision, and a jury found she suffered a materially adverse change in her employment terms and awarded damages; the court of appeals affirmed, and the Supreme Court granted certiorari.
Whether Title VII's anti-retaliation provision applies only to retaliatory actions that affect the terms and conditions of employment, or extends more broadly to any materially adverse action that would deter a reasonable employee from engaging in protected activity.