Title VII Retaliation Claims after White: The Struggle to Define Materially Adverse Conduct in the Context of the Reasonable Employee Standard

On June 22, 2006, the U.S. Supreme Court issued its opinion in Burlington Northern & Santa Fe Railway Co. v. White and resolved a split among the circuit courts regarding the correct interpretation of the anti-retaliation provision contained in Title VII of the Civil Rights Act of 1964, as amended (“Title VII”)...