Case Citator › Cynthia A. Richardson v. New York State Department of Correctional Service, Auburn Correctional Facility

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.

Abrogated
Court
Second Circuit
Citation
180 F.3d 426
Decided
Confirmed treatments
1
Flagged citations read
104 of 104
Citing cases (total)
692
Treatment dates
2006

Status

Abrogated
A reviewed court treats this case as abrogated by later authority. Cynthia A. Richardson v. New York State Department of Correctional Service, Auburn Correctional Facility is abrogated in part by the one confirmed treatment listed below; every flagged citation has been read. Burlington Northern & Santa Fe Railway Co. v. White displaced Richardson's requirement that actionable Title VII retaliation materially change the terms and conditions of employment.
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.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

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 →

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