Second Circuit -- Rivera v. Rochester Genesee Regional Transportation Authority

District Court erred in granting SJ against Title VII plaintiff, given hostility of work environment, language used.

Title VII does not require that the retribution happen before the protected conduct.  (Yes.)

Retribution claim correctly dismissed, as there were bona fide reasons for the adverse employment action.

Second retribution claim incorrectly dismissed, due to proximacy of conduct and subsequent action.

District court erred in dismissing the state law claims - jurisdiction is proper.

Rivera v. Rochester Genesee Regional Transportation Authority