Ponce v. Billington, No. 11-5117 (D.C. Cir. 2012)
Annotate this CasePlaintiff applied for a position as Director of the Library of Congress and when he was passed over for the job, he claimed that the Library of Congress violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. On appeal, defendant sought a new trial, arguing that the district court erred by instructing the jury that he had to prove that unlawful discrimination was the "sole reasons" for his non-selection. Although the court agreed that "sole reason" was not the correct standard, the jury instructions themselves corrected any error by defining "sole reasons" as "but-for" causation. The court recognized, however, that its recent Title VII employment discrimination cases have caused some confusion and the court took the opportunity to clarify the requirements the statute placed upon plaintiffs and the courts.
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