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September 2014

Fourth Circuit Reaffirms Retaliation Temporal Proximity Standard

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The Fourth Circuit recently issued an unpublished decision in Ranade v. BT Americas.  Ranade brought claims against BT for FMLA retaliation and interference.  After discovery, BT moved for summary judgment, arguing that Ranade’s retaliation claims failed because the temporal proximity between her protected activity and BT America’s adverse employment action was too remote.  BT Americas also moved for summary judgment on Ranade’s FMLA interference claim. The Fourth Circuit granted BT’s motion for summary judgment.  In doing so, the Court reaffirmed its prior caselaw that a six month gap between protected activity and adverse employment action is too remote to support…

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