Analysis: The “No Blood No Foul” Rule. When is an Employer’s Conduct Severe Enough to Constitute Retaliation?

I pre­vi­ous­ly wrote about the Supreme Court’s retal­i­a­tion deci­sion in Burling­ton North­ern & Sante Fe Rail­way Co. v. White, 548 U.S. 53 (2006) (“Burling­ton North­ern v. White”), in which the US Supreme Court sub­stan­tial­ly broad­ened the abil­i­ty of employ­ees to file retal­i­a­tion claims under Title VII of the Civ­il Rights Act of 1964. It was a unan­i­mous (9–0) decision.

National Basketball Association I want­ed to set out some addi­tion­al thoughts about Burling­ton North­ern, because it address­es an issue that has trou­bled the courts in inter­pret­ing the fed­er­al anti-dis­crim­i­na­tion laws: When is an employ­er’s con­duct seri­ous enough in dis­ad­van­tag­ing an employ­ee so that the employ­ee has a claim under the employ­ment dis­crim­i­na­tion laws? The answer is easy when the employ­er’s deci­sion affects the employ­ee’s pock­et book, like with ter­mi­na­tion, fail­ure to hire, demo­tions, and the like. The answer has been much hard­er when the employ­er’s con­duct did­n’t direct­ly affect the employ­ee’s pock­et book.

NBA ref­er­ees strug­gle with a sim­i­lar issue: where is there enough phys­i­cal con­tact on the court to jus­ti­fy call­ing a foul on a play­er. So let’s explore some par­al­lels between these employ­ment dis­crim­i­na­tion issues and the NBA’s “no blood no foul” rule.

The NBA’s “No Blood No Foul” Rule

If you watch Nation­al Bas­ket­ball Asso­ci­a­tion games, you might be struck by how much phys­i­cal con­tact there is on the court and how rarely the ref­er­ees call per­son­al fouls over that phys­i­cal con­tact. Fans of the NBA have only a par­tial­ly kid­ding way to refer to the “stan­dard” by which the ref­er­ees decide how much con­tact will result in a per­son­al foul being called. It’s the “no blood no foul” rule. In oth­er words, the ref­er­ees will allow a lot of phys­i­cal con­tact, and will only call a foul when some­one gets blood­ied as a result of the con­tact.

Let’s assume, with our tongues in our cheeks, that there is such a rule (no blood no foul) that NBA ref­er­ees apply, regard­less of what is writ­ten in the Offi­cial Rules. The idea behind the “no blood no foul” rule is this: there is so much fast-paced hur­ley-burly con­tact on the bas­ket­ball court, much of which makes it more excit­ing for the fans, that call­ing a foul for any phys­i­cal con­tact (or a low­er defined lev­el of phys­i­cal con­tact) would slow down the game for fans and make the game less enjoy­able, unrea­son­ably impede the skill of the play­ers, and makes it impos­si­bly hard for offi­cials to iden­ti­fy “con­tact”. So the appear­ance of blood is a more “objec­tive” indi­ca­tion that the con­tact real­ly mat­tered and real­ly con­sti­tut­ed an unfair inter­fer­ence with the oth­er player.

The Supreme Court Struggles With “When is There a Foul”?

Courts for years have strug­gled with the employ­ment dis­crim­i­na­tion equiv­a­lent of the “no blood no foul” rule. For the courts, assum­ing unlaw­ful dis­crim­i­na­tion occurred: when is the con­se­quence of the dis­crim­i­na­tion seri­ous enough and objec­tive­ly dis­cernible so that courts will rec­og­nize a claim and inter­vene by acti­vat­ing the court’s process and poten­tial­ly award­ing damages.

Except for sit­u­a­tions involv­ing hos­tile work envi­ron­ment, the courts have trans­lat­ed the NBA’s blood require­ment into a tan­gi­ble eco­nom­ic con­se­quence. Thus, much in the spir­it of the NBA, the courts have said eco­nom­ic harm must be demon­stra­ble as a result of dis­crim­i­na­tion, or else the courts won’t enter­tain the claim no eco­nom­ic con­se­quence, no legal vio­la­tion, case dismissed.

Three Approaches on Whether There is a Discrimination Foul 

Before the supreme court’s deci­sion in Burling­ton North­ern, the courts had strug­gled over, in effect, how much blood to require, or even whether to require any blood at all.

We need to put aside, for the moment, claims involv­ing a hos­tile work envi­ron­ment. In such claims, there is no “blood” require­ment. The courts rec­og­nize claims for hos­tile work envi­ron­ment, and will award dam­ages, even where there is no eco­nom­ic con­se­quence, as long as the plain­tiff proves that the envi­ron­ment issue was severe or per­va­sive enough so as to inter­fere with what he an employ­ee’s work envi­ron­ment. That sit­u­a­tion, where the courts do not require any eco­nom­ic con­se­quence, is the excep­tion rather than the rule.

So for retal­i­a­tion claims, the courts have his­tor­i­cal­ly adopt­ed three dif­fer­ent tests for deter­min­ing the min­i­mal lev­el of sever­i­ty required before the court will rec­og­nize a claim for the employ­ee. The fol­low­ing options start with the most severe lev­el of mis­con­duct the rough equiv­a­lent of blood ver­i­ta­bly gush­ing out of the NBA player:

First, some courts have only rec­og­nized a claim if there had been an “ulti­mate employ­ment deci­sion” in retal­i­a­tion for an employ­ee’s oppo­si­tion to dis­crim­i­na­to­ry con­duct. “Ulti­mate employ­ment deci­sions” are things like hir­ing, grant­i­ng leave, dis­charg­ing, pro­mot­ing, and compensating.

Sec­ond, mov­ing down in terms of the lev­el of sever­i­ty, some courts had rec­og­nized a claim where there had been an “adverse effect” on the “terms, con­di­tions, or ben­e­fits” of employ­ment. That is a broad­er test because it encom­pass­es con­duct by the employ­er that is on a low­er lev­el than the “ulti­mate employ­ment deci­sions.” For exam­ple, sup­pose an employ­er neg­a­tive­ly eval­u­ates an employ­ee so that the neg­a­tive eval­u­a­tion results in a low­er raise. Under the “ulti­mate employ­ment deci­sion” stan­dard, a per­for­mance eval­u­a­tion does not ring the bell. But under the stan­dard of an adverse affect on the “terms, con­di­tions, or ben­e­fits” of employ­ment, the neg­a­tive eval­u­a­tion would be includ­ed, poten­tial­ly pro­vid­ing the sup­port for the claim of retaliation.

Third, some courts have aban­doned any blood require­ment at all. The Supreme Court rec­og­nized that there was a dif­fer­ent rule in terms of the require­ment for a spe­cif­ic lev­el of sever­i­ty between the sub­stan­tive dis­crim­i­na­tion pro­vi­sion of Title VII and the retal­i­a­tion pro­vi­sion. Eco­nom­ic con­se­quence was required under the sub­stan­tive dis­crim­i­na­tion pro­vi­sions, but not under the retal­i­a­tion pro­vi­sion. This dis­tinc­tion was tied close­ly to the dif­fer­ent lan­guage in the pro­hi­bi­tion sec­tions on dis­crim­i­na­tion and retaliation.

Substantive Prohibitions Versus Retaliation Prohibitions

Since this third approach is tied close­ly to a care­ful­ly read­ing of Title VII’s retal­i­a­tion pro­vi­sion, let’s look at the dif­fer­ence between the sub­stan­tive and retal­i­a­tion pro­vi­sions in Title VII (and a good but of the Supreme Court’s analy­sis in Burling­ton North­ern v. White was based on the dif­fer­ence between these provisions).

Sec­tion 703(a) of Title VII con­tains the sub­stan­tive anti-dis­crim­i­na­tion pro­vi­sion: “it shall be an unlaw­ful employ­ment prac­tice for an employ­er (1) to fail or refuse to hire or to dis­charge any indi­vid­ual, or oth­er­wise to dis­crim­i­nate against any indi­vid­ual with respect to his com­pen­sa­tion, terms, con­di­tions, or priv­i­leges of employ­ment, because of such indi­vid­u­al’s race, col­or, reli­gion, sex, or nation­al ori­gin; or (2) to lim­it, seg­re­gate, or clas­si­fy his employ­ees or appli­cants for employ­ment in any way which would deprive or tend to deprive any indi­vid­ual of employ­ment oppor­tu­ni­ties or oth­er­wise adverse­ly affect his sta­tus as an employ­ee, because of such indi­vid­u­al’s race, col­or, reli­gion, sex, or nation­al ori­gin.” 42 U.S.C. § 2000e‑2(a).

The anti-retal­i­a­tion pro­vi­sion of title VII, in sec­tion 704(a), has a dif­fer­ent pro­hi­bi­tion pro­vi­sion: “It shall be an unlaw­ful employ­ment prac­tice for an employ­er to dis­crim­i­nate against any of his employ­ees or appli­cants for employ­ment because he has opposed any prac­tice made an unlaw­ful employ­ment prac­tice by this sub­chap­ter, or because he has made a charge, tes­ti­fied, assist­ed, or par­tic­i­pat­ed in any man­ner in any inves­ti­ga­tion, pro­ceed­ing, or hear­ing under this sub­chap­ter.” 42 U.S.C. § 2000e‑3(a).

The Supreme Court in Burling­ton North­ern v. White not­ed that the key words in the sub­stan­tive pro­vi­sion “hire,” “dis­charge,” “com­pen­sa­tion, terms, con­di­tions, or priv­i­leges of employ­ment,” employ­ment oppor­tu­ni­ties,” and “sta­tus as an employ­ee” “explic­it­ly lim­it the scope of that pro­vi­sion to actions that affect employ­ment or alter the con­di­tions of the work­place. No such lim­it­ing words appear in the anti-retal­i­a­tion pro­vi­sion.” This is at pages 2411–2412.

The sub­stan­tive pro­vi­sion seeks to pre­vent injury to indi­vid­u­als based on who they are, i.e., their sta­tus. The anti-retal­i­a­tion pro­vi­sions seek to pre­vent harm to indi­vid­u­als based on what they do, i.e., their conduct.”

The Supreme Court rec­og­nized that the lan­guage in the retal­i­a­tion pro­vi­sion was not lim­it­ed to con­duct in the work­place. “An employ­er can effec­tive­ly retal­i­ate against an employ­ee by tak­ing actions not direct­ly relat­ed to his employ­ment or by caus­ing him harm out­side the work­place.” Exam­ples that the court not­ed, from ear­li­er deci­sions, were: an employ­ee of the FBI com­plained, and the FBI retal­i­at­ed by refus­ing to inves­ti­gate death threats a fed­er­al pris­on­er had made against the employ­ee. Anoth­er exam­ple: the employ­er filed false crim­i­nal charges against a for­mer employ­ee who com­plained about discrimination.

A pro­vi­sion lim­it­ed to employ­ment-relat­ed actions would not deter the many forms of effec­tive retal­i­a­tion can take. Hence, such a lim­it­ed con­struc­tion would fail to ful­ly achieve the anti-retal­i­a­tion pro­vi­sion’s “pri­ma­ry pur­pose”, name­ly, “[m]aintaining unfet­tered access to statu­to­ry reme­di­al mechanisms.”

Thus, “the pur­pose rein­forces what lan­guage already indi­cates”, that the “anti-retal­i­a­tion pro­vi­sion, unlike the sub­stan­tive pro­vi­sion, is not lim­it­ed to dis­crim­i­na­to­ry actions that affect the terms and con­di­tions of employment.”

Key Ruling: “Materially Adverse” Action

The Supreme Court posed the issue as address­ing “the lev­el of seri­ous­ness to which this harm must rise before it becomes action­able retal­i­a­tion.” The Supreme Court agreed with the Sev­enth and Dis­trict of Colum­bia Cir­cuits. The Supreme Court con­clud­ed that “a plain­tiff must show that a rea­son­able employ­ee would have found the chal­lenged action mate­ri­al­ly adverse, which in this con­text means it well might have dis­suad­ed a rea­son­able work­er from mak­ing or sup­port­ing a charge of discrimination””.

The Supreme Court said that it described the rule in terms of “mate­r­i­al adver­si­ty” to sep­a­rate “sig­nif­i­cant from triv­ial harms.” There is no “gen­er­al civil­i­ty code for the Amer­i­can work­place.” The “ordi­nary tribu­la­tions of the work­place, such as the spo­radic use of abu­sive lan­guage, gen­der-relat­ed jokes, and occa­sion­al teas­ing” must be fil­tered out of the uni­verse of claims that the courts will rec­og­nize. The law will not “immu­nize” the employ­ee from those “pet­ty slights or minor annoy­ances that often take place at work and that all employ­ees expe­ri­ence.” “Per­son­al­i­ty con­flicts at work that gen­er­ate antipa­thy and snub­bing by super­vi­sors and cowork­ers are not action­able” under Title VII. So “nor­mal­ly pet­ty slights, minor annoy­ances, and sim­ple lack of good man­ners will not cre­ate such deterrence.”

The rule was stat­ed in terms of a “rea­son­able employ­ee” because the “stan­dard for judg­ing harm” must be “objec­tive.” An objec­tive stan­dard is “judi­cial­ly admin­is­tra­ble.” That stan­dard avoids the “uncer­tain­ties and unfair dis­crep­an­cies” that can “plague a judi­cial effort to deter­mine a plain­tiff’s unusu­al sub­jec­tive feelings.”

Materially Adverse” Action versus “Petty Slights”

The court gave fur­ther exam­ples of how to dis­tin­guish between “pet­ty slights” and “mate­r­i­al” changes that might deter a rea­son­able employ­ee from com­plain­ing about dis­crim­i­na­tion. For exam­ple, while a “sched­ule change in an employ­ee’s work sched­ule may make lit­tle dif­fer­ence to many work­ers, it may mat­ter enor­mous­ly to a young moth­er with school age chil­dren.” The court cit­ed one exam­ple of an employ­ee with a dis­abled child need­ing flex-time scheduling.

The super­vi­sor’s refusal to invite an employ­ee to lunch is nor­mal­ly triv­ial. But to retal­i­ate by “exclud­ing an employ­ee from the week­ly train­ing lunch that con­tributes sig­nif­i­cant­ly to the employ­ee’s pro­fes­sion­al advance­ment might well deter a rea­son­able employ­ee from com­plain­ing about dis­crim­i­na­tion.” The court not­ed that whether action is sig­nif­i­cant­ly adverse “will often depend upon the par­tic­u­lar cir­cum­stances. Con­text mat­ters.” An act that would be “imma­te­r­i­al in some sit­u­a­tions is mate­r­i­al in others.”

The stan­dard is tied to the “chal­lenged retal­ia­to­ry act, not the under­ly­ing con­duct that forms the basis of the Title VII complaint.”

The key in exam­in­ing the employ­er’s chal­lenged retal­ia­to­ry action is to “screen out triv­ial con­duct while effec­tive­ly cap­tur­ing those acts that are like­ly to dis­suade employ­ees from com­plain­ing or assist­ing in com­plaints about discrimination.”

In the case, the employ­ee had been assigned from fork­lift duty, which was con­sid­ered desir­able, to stan­dard track labor tasks.

Com­mon sense sug­gests that one good way to dis­cour­age an employ­ee such as White from bring­ing dis­crim­i­na­tion charges would be to insist that she spent more time per­form­ing the more ardu­ous duties and less time per­form­ing those that are eas­i­er or more agree­able.” Thus, one of the cat­e­gories of adverse retal­ia­to­ry action that did not require finan­cial con­se­quence was “unpleas­ant work assignments.”

How­ev­er, reas­sign­ment of job duties is not “auto­mat­i­cal­ly action­able.” Whether a par­tic­u­lar reas­sign­ment is “mate­ri­al­ly adverse” “depends upon the cir­cum­stances of the par­tic­u­lar case” and should be judged from the “per­spec­tive of a rea­son­able employ­ee in the plain­tiff’s posi­tion, con­sid­er­ing all the circumstances.”

The court also found that the fact that the employ­er sus­pend­ed White for 37 days with no pay was a mate­ri­al­ly adverse action, even though the lost income was lat­er paid to the employ­ee. An “indef­i­nite sus­pen­sion with­out pay could well act as a deter­rent, even if the sus­pend­ed employ­ee even­tu­al­ly received back pay.”

Justice Alito’s Concurring Opinion

Jus­tice Ali­to wrote a con­cur­ring opin­ion in which he con­curred in the judg­ment. He would have applied the con­ven­tion­al require­ment that the adverse employ­ment action must con­sti­tute a “tan­gi­ble employ­ment action”, and he thought the reas­sign­ment to the sub­stan­tial­ly less desir­able posi­tion and duties con­sti­tut­ed such an “adverse employ­ment action.”

He was con­cerned about part II‑D of the Court’s opin­ion, in which the court con­clud­ed that the only thresh­old require­ment was mate­ri­al­ly adverse action that would dis­suade a rea­son­able employ­ee from com­plain­ing about dis­crim­i­na­tion. He thought that test was unnec­es­sary, and that the court should have employed the test requir­ing some tan­gi­ble effect on the com­pen­sa­tion, terms, con­di­tions, or priv­i­leges of employment.

Jus­tice Ali­to describes a num­ber of poli­cies (“pur­pos­es”) behind the anti-retal­i­a­tion pro­vi­sion in Title VII: (1) pre­vent­ing employ­ers from engag­ing in retal­ia­to­ry mea­sures which will dis­suade employ­ees from engag­ing in pro­tect­ed activ­i­ty, and (2) pre­vent harm to indi­vid­u­als that assert their rights.

The Take-Away Rules in Burlington Northern v. White

The Supreme Court broad­ened retal­i­a­tion claims in 2 ways:

First: Retal­ia­to­ry con­duct is not lim­it­ed to an employ­er’s action at the work­place, and it is not lim­it­ed to action tak­en while the plain­tiff is still work­ing for the employer.

Sec­ond: Action by the employ­er may vio­late the anti-retal­i­a­tion pro­vi­sion even if it does not cause a tan­gi­ble loss, such as pay, for the plain­tiff. The con­duct may vio­late the law if it is “mate­ri­al­ly adverse” (as opposed to “triv­ial”) to the employ­ee, and might dis­suade a “rea­son­able work­er” from “mak­ing or sup­port­ing a charge of dis­crim­i­na­tion”. So, for exam­ple, trans­fers to dif­fer­ent posi­tions, even though they involve no loss in pay or ben­e­fits or pro­mo­tion­al oppor­tu­ni­ties, might con­sti­tute unlaw­ful action because, if the trans­fer is to what a rea­son­able work­er would view as a less attrac­tive job, that might dis­suade a rea­son­able work­er from com­plain­ing of discrimination.

Finally, Back to the NBA

After all of this legal stuff, grab a beer and watch the NBA “Top Sto­ry” on ESPN (the video from this wid­get may not work on some mobile phone browsers):

Final­ly, but only if you are hard­core NBA fan, read the NBA’s Rule 12, Part B on “Per­son­al Foul”, under Sec­tion I “Types”. This will give you the NBA’s real rule on per­son­al fouls:

a. A play­er shall not hold, push, charge into, impede the progress of an oppo­nent by extend­ing a hand, fore­arm, leg or knee or by bend­ing the body into a posi­tion that is not nor­mal. Con­tact that results in the re-rout­ing of an oppo­nent is a foul which must be called imme­di­ate­ly.
b. Con­tact ini­ti­at­ed by the defen­sive play­er guard­ing a play­er with the ball is not legal. This con­tact includes, but is not lim­it­ed to, fore­arm, hands, or body check.
EXCEPTIONS:
(1) A defend­er may apply con­tact with a fore­arm to an offen­sive play­er with the ball who has his back to the bas­ket below the free throw line extend-ed out­side the Low­er Defen­sive Box.
(2) A defend­er may apply con­tact with a fore­arm and/or one hand with a bent elbow to an offen­sive play­er in a post-up posi­tion with the ball in the Low­er Defen­sive Box.
(3) A defend­er may apply con­tact with a fore­arm to an offen­sive play­er with the ball at any time in the Low­er Defen­sive Box. The fore­arm in the above excep­tions is sole­ly for the pur­pose of main­tain­ing a defen­sive posi­tion.
(4) A defend­er may posi­tion his leg between the legs of an offen­sive play­er in a post-up posi­tion in the Low­er Defen­sive Box for the pur­pose of main­tain­ing defen­sive posi­tion. If his foot leaves the floor in an attempt to dis-lodge his oppo­nent, it is a foul imme­di­ate­ly.
(5) Inci­den­tal con­tact with the hand against an offen­sive play­er shall be ignored if it does not affect the play­er’s speed, quick­ness, bal­ance and/or rhythm.
c. Any play­er whose actions against an oppo­nent cause ille­gal con­tact with yet anoth­er oppo­nent has com­mit­ted the per­son­al foul.
d. A per­son­al foul com­mit­ted by the offen­sive team dur­ing a throw-in shall be an offen­sive foul, regard­less of whether the ball has been released.
e. Con­tact which occurs on the hand of the offen­sive play­er, while that hand is in con­tact with the ball, is legal.
EXCEPTION: Fla­grant, elbow and punch­ing fouls.

Drew M. Capuder
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