Case Citator › Anna M. Jensen v. Jack E. Potter, Postmaster General Us Postal Service

Anna M. Jensen v. Jack E. Potter, Postmaster General Us Postal Service

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Third Circuit
Citation
435 F.3d 444
Decided
Confirmed treatments
1
Flagged citations read
95 of 95
Citing cases (total)
265
Treatment dates
2006
Abrogated
A reviewed court treats this case as abrogated by later authority. Anna M. Jensen v. Jack E. Potter is abrogated in part among the reviewed cases: all 95 flagged citations have been read, and the one confirmed treatment is listed below. Moore v. City of Philadelphia recognized that Burlington Northern & Santa Fe Railway Co. v. White displaced Jensen's requirement that retaliatory harassment be severe or pervasive enough to alter employment terms, replacing it with the materially-adverse-action standard.
More on how this was screened

Jensen's recognition of retaliatory hostile-work-environment claims, causation analysis, and coworker-harassment liability rules remain in use. The queued opinions applied those surviving rules or repeated Burlington Northern's treatment without independently wounding Jensen.

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.

265 later cases cite Anna M. Jensen v. Jack E. Potter, Postmaster General Us Postal Service; 95 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 Anna M. Jensen v. Jack E. Potter, Postmaster General Us Postal Service?

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 Third Circuit recognized that Burlington Northern displaced Jensen's severe-or-pervasive threshold for Title VII retaliation and replaced it with the materially-adverse-action standard.

    Myrna Moore v. City of Philadelphia · Third Circuit · filed

    In Burlington Northern, decided after the District Court's opinion in this case, the Supreme Court disagreed with a formulation like the one we adopted in Robinson and Jensen. 126 S.Ct. at 2410 (citing Robinson, 120 F.3d at 1300, as an example of this standard). It found that the discrimination and retaliation provisions of Title VII have different statutory language and different purposes, and accordingly, "that the anti-retaliation provision, unlike the substantive provision, is not limited to discriminatory actions that affect the terms and conditions of employment."
    Read the full opinion on CourtListener →

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