Portal:United States Court of Appeals for the Fifth Circuit

“ In Hoffman, the Mississippi Supreme Court stated that the issue before the court was whether Hoffman breached his contract, not “whether [Hoffman’s] employer has failed to act upon similar past deficiencies.” [10] But here, unlike in Hoffman, [11] the question of breach implicates Jackson State’s past handling of similar situations because the jury had to decide whether Taylor performed her duties in good faith and whether any violations she committed were deliberate, serious, and willful. ”

“ Accordingly, Lowrey did not announce a sole causation standard for Title IX retaliation claims; it suggested that the causation standard for Title IX claims should be the same as the causation standard for Title VII claims while clarifying that complaints about conduct barred by Title VII could not form the basis of a Title IX claim.
Regardless, a new trial is not warranted because the district court’s instruction “substantially covered” [42] the correct standard: that there must be a “causal connection” between the Title IX complaint and the adverse employment action. ”

“ Accordingly, the statement that Taylor can only prevail if she was terminated “solely as a consequence of complaints alleging noncompliance with the substantive provisions of Title IX” should be read as distinguishing complaints about noncompliance with Title IX from “complaints related to [Taylor’s] own individual employment,” not as establishing a causation standard. ”

“ Kennedy, 713 F.3d 237, 242 (5th Cir. 2013) ) . ↑ Id. (quoting Anderson v. Sch. Bd. of Madison Cty., 517 F.3d 292, 296 (5th Cir. 2008) ) . ↑ Franklin Collection Serv., Inc. v. Kyle, 955 So. 2d 284, 291 (Miss. 2007) ; Young v. ”