“But-For This,” “But-For That” -- Multiple “But-For” Causes Possible In Title VII Retaliation Claim
The Second Circuit Court of Appeals delivered Zann Kwan an early Christmas present earlier this month when it concluded that her former employer was not entitled to summary judgment on her retaliation claim. Zann Kwan v. Andalex Grp. LLC, No. 12-2493 (2d Cir. Dec. 16, 2013). From April 2007 until September 2008 Zann Kwan worked as the Vice President of Acquisitions for The Andalex Group, a small family-owned real estate management company based...
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