Promotion After Protected Activity Dooms Employee’s Retaliation Claim

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What does unlawful retaliation not look like? Burton v. Board of Regents of Univ. of Wisc. Sys. (7th Cir. 3/17/17) offers a good example.

Sabina Burton, a tenured track professor at the University of Wisconsin, claimed that she suffered retaliation after complaining about witnessing sexual harassment within her department. As a result, she claimed that her colleagues withdrew support for a new curriculum for which she had been advocating. Ultimately, however, the court concluded that a promotion and pay raise after Burton’s claimed protected activity doomed her retaliation claim.

Professor Burton undoubtedly feels that she has been treated unfairly by some of

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