Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006)
Primary Holding
The anti-retaliation provision of Title VII of the Civil Rights Act of 1964 protects employees from employer actions that would dissuade a reasonable worker from making or supporting a charge of discrimination, and it is not limited to actions that affect the terms and conditions of employment or occur at the workplace.
In the case of Burlington Northern & Santa Fe Railway Co. v. White, a woman named Sheila White faced unfair treatment at work after she complained about discrimination. The Supreme Court ruled that employers cannot retaliate against employees for speaking up about discrimination, even if the retaliation happens outside of the workplace or doesn't directly affect their job duties. This case is important for consumers because it strengthens workers' rights to report discrimination without fear of being punished, making it easier for people to stand up for themselves in similar situations.
AI-generated plain-language summary to help you understand this case
In Burlington Northern & Santa Fe Railway Co. v. White, the underlying dispute arose from the treatment of Sheila White, the only female employee in the Maintenance of Way department at Burlington's Tennessee Yard. After being hired as a track laborer in June 1997, White was assigned to operate a forklift, a responsibility she had experience with. However, in September 1997, after White complained about her supervisor Bill Joiner's discriminatory remarks regarding women in the department, Burlington suspended Joiner for ten days and mandated sexual harassment training. Following this disciplinary action, White was reassigned from her forklift duties to standard laborer tasks, which was justified by Burlington as a response to complaints from male co-workers who believed a more senior male employee should operate the forklift. The procedural history of the case began when White filed a complaint with the Equal Employment Opportunity Commission (EEOC) on October 10, 1997, alleging retaliation for her complaint against Joiner. After receiving a right-to-sue letter from the EEOC, White filed a lawsuit in the U.S. District Court for the Western District of Tennessee. The district court ruled in favor of Burlington, but the decision was appealed to the U.S. Court of Appeals for the Sixth Circuit, which reversed the lower court's ruling, leading Burlington to seek certiorari from the Supreme Court. The relevant background context includes the provisions of Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination and retaliation against individuals who oppose discriminatory practices. The case raised significant questions about the scope of the anti-retaliation provision, particularly whether it only applied to actions affecting the terms and conditions of employment and how harmful employer actions must be to qualify as retaliation. The Supreme Court's decision ultimately clarified that the anti-retaliation provision protects employees from actions that would dissuade a reasonable worker from making or supporting a charge of discrimination, regardless of whether those actions occurred in the workplace.
Whether the anti-retaliation provision of Title VII of the Civil Rights Act of 1964 protects employees from employer actions that are materially adverse, even if those actions do not affect the terms and conditions of employment or occur at the workplace.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- April 17, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
Whitman v. Department of Transportation, 547 U.S. 512 (2006)
Mixed OutcomeThe Court held that the jurisdiction of federal courts to review employment-related claims of federal employees is not conferred by 5 U.S.C. §7121(a)(1), but such jurisdiction is not divested by the Civil Service Reform Act (CSRA), allowing for potential claims to be pursued under 28 U.S.C. §1331 if they arise under the Constitution or federal law.
Jackson v. Birmingham Bd. of Ed., 544 U.S. 167 (2005)
Consumer WonTitle IX of the Education Amendments of 1972 encompasses claims of retaliation against individuals who complain about sex discrimination in educational programs, thereby allowing for a private right of action in such cases.
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006)
Consumer WonThe numerical threshold of having "fifteen or more employees" in Title VII's definition of "employer" does not affect federal-court subject-matter jurisdiction but instead relates to the substantive adequacy of a Title VII claim for relief, and thus cannot be raised as a defense late in the litigation.
Ash v. Tyson Foods, Inc., 546 U.S. 454 (2006)
Mixed OutcomeThe use of the term "boy" by an employer in reference to African-American employees can be considered evidence of discriminatory animus, and the standard for determining whether an employer's stated nondiscriminatory reasons for hiring decisions are pretextual should not require modifiers or qualifications to be probative of bias.