Susan Strouss v. Michigan Department of Corrections, a State Agency and Body Politic Marie Fletcher Gerald Devoss, in Their Individual Capacities

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that a lateral transfer could be an adverse employment action “if the conditions of the transfer would have been objectively intolerable to a reasonable person”
• noting that three years was a “significant gap in time between the protected activity and the adverse action” that cannot be used to “give rise to an inference of a retaliatory motive”
• finding retaliation claims based on conduct that occurred before EEOC charge filling must be included in that charge
• noting in dicta that a First Amendment retaliation claim based on complaints about sexual harassment, which is a specific form of sex discrimination, would be viable because such complaints are a matter of public concern
• “[F]ederal courts do not have subject matter jurisdiction to hear Title VII claims unless the claimant explicitly files the claim in an EEOC charge or the claim can be reasonably expected to grow out of the EEOC charge.”

Source: CourtListener parenthetical corpus (CC0).