Retaliation · Federal · Title VII
Burlington Northern & Santa Fe Railway Co. v. White
548 U.S. 53 · Supreme Court of the United States · 2006
A forklift operator — the only woman in her maintenance department — complained that her supervisor made repeated sexually offensive remarks. She was removed from forklift duty to more arduous standard track labor, and later suspended without pay for 37 days before the suspension was reversed and back pay awarded.
The Court held that a retaliation claim does not require a firing or a pay cut. Reassignment of duties and a suspension later reversed can each be materially adverse if they would dissuade a reasonable worker from complaining.
Jury verdict for the employee, affirmed
Reported outcome
Judgment for the employee affirmed; the Court adopted the “materially adverse” standard for retaliation.
Completeness reading
94/100
ignita-completeness-v1 · illustrative
Preview. Not legal advice. Attorney-reviewed: false.
The events, kept in order.
Drawn from the reported decision. Nothing is interpreted at this stage — each entry simply holds when it happened and what happened.
Step 1
Internal complaint about a supervisor's conduct
The employee reported repeated sexually offensive remarks by her immediate supervisor to company officials.
Protected activity or key conduct
Step 2
Removed from forklift duty
Days after the internal complaint she was reassigned from operating the forklift to standard, more physically arduous track labor at the same pay grade.
Step 3
Second internal charge filed
She filed a charge asserting the reassignment was retaliatory.
Protected activity or key conduct
Step 4
Suspended without pay
Following a dispute with another supervisor she was suspended without pay for 37 days; the suspension was later reversed with back pay.
What the engine reads here
The record's strength is structural, not emotional: a dated complaint, a documented duty change days later, then a second adverse action months after that. Two separable adverse events tied to one protected act is the shape Ignita is built to surface early.
Pattern and class signal
Individual pattern. One department, one complainant — but the duty-reassignment mechanism is the kind of practice that repeats across a workforce, which is where a single record becomes a pattern question.
Preview. Not legal advice. Attorney-reviewed: false.
Your own record
Every matter here began as small, ordinary entries someone almost didn't keep.