Law360 ( October 19, 2006, 12:00 AM EDT) -- In Burlington Northern & Santa Fe Railway Co. v. White, 126 S.Ct 797 (2006), the Supreme Court unanimously ruled that the scope of Title VII's anti-retaliation provision, which forbids "discrimina[tion] against" an employee or applicant who, inter alia, has "made a charge, testified, assisted, or participated in" a Title VII proceeding or investigation, extends beyond actions that affect terms and conditions of employment....
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