Not all retaliation laws are alike. There’s one that doesn’t even require any intent to retaliate.

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There are all sorts of anti-retaliation laws that protect employees. Many require that employees who invoke them prove that the employer acted with retaliatory intent.

But not all of them.

Last week, the Supreme Court agreed unanimously in Murray v. UBS Securities that the one that protects whistleblowers who speak up about corporate fraud or securities law violations at publicly traded companies must prove that their protected activity (i.e., whistleblowing) was a contributing factor in the employer’s unfavorable personnel action, but need not prove that his employer acted with “retaliatory intent.”

So, how exactly does an employer retaliate without

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