At a Glance
This Littler Lightbulb highlights some of the more significant employment law developments in the federal courts of appeal in the last month.
Fifth Circuit Affirms Judgment for Employer on Title IX and Title VII Retaliation Claims
In Lewis v. Board of Supervisors of LSU, __ F.4th __ (5th Cir. Apr. 8, 2025), a former employee of a university football department who held various positions, including recruiting and alumni relations, internally reported that the assistant coach and recruiting coordinator sexually harassed and assaulted her and others. After she was terminated from employment, she filed suit alleging, among other things, retaliation for reporting the harassment, in violation of Title IX and Title VII. In response, the university argued that the plaintiff was terminated from employment, along with about 40 others in the football program, as part of a new head coach’s initiative to reorganize the recruiting department and hire his own staff. After a six-day trial, the jury returned a verdict in favor of the university on all claims, and the plaintiff appealed.
Under both Title IX and Title VII, the Fifth Circuit stated, the plaintiff “must show a causal connection between the protected activity and the adverse action.” The plaintiff in this case failed to “put forth the strong and overwhelming evidence needed to reverse” a jury verdict, the court held. Reviewing the trial transcript, the court found there was ample evidence that the plaintiff was...
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