Cynthia A. Richardson v. New York State Department of Correctional Service, Auburn Correctional Facility
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Later opinions positively applied Richardson's unaffected hostile-work-environment, temporal-causation, employer-liability, and immunity holdings while copying history parentheticals that reported the Supreme Court's intervening rule; none supplied a separate adverse treatment.
692 later cases cite Cynthia A. Richardson v. New York State Department of Correctional Service, Auburn Correctional Facility; 104 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Cynthia A. Richardson v. New York State Department of Correctional Service, Auburn Correctional Facility?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Abrogated
-
The Supreme Court abrogated Richardson's rule limiting actionable Title VII retaliation to a materially adverse change in the terms and conditions of employment, holding that retaliation may occur outside the workplace and is actionable when it could dissuade a reasonable worker from protected activity.
Burlington Northern & Santa Fe Railway Co. v. White · Supreme Court of the United States · filed
We conclude that the antiretaliation provision does not confine the actions and harms it forbids to those that are related to employment or occur at the workplace. We also conclude that the provision covers those (and only those) employer actions that would have been materially adverse to a reasonable employee or job applicant.
Read the full opinion on CourtListener →
Does this case still carry your argument?
Describe your facts. Ezel reads Cynthia A. Richardson v. New York State Department of Correctional Service, Auburn Correctional Facility and the cases that treated it, then tells you whether it still holds for your situation, with citations.
Opens in Ezel Pro.
- Checks the law as it stands today, not only this page
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace