Leitgen v. Franciscan Skemp Healthcare, Inc., 09-1496, concerned a plaintiff's suit against her former employer under Title VII of the Civil Rights Act of 1964 claiming that it retaliated against her by forcing her to resign after she complained that its compensation scheme unlawfully underpaid physicians based on gender.
In affirming the district court's grant of summary judgment in favor of
the employer, the court held that to establish a causal connection
between plaintiff's allegedly protected conduct and her forced
resignation, she had to show that her complaints were "a substantial or
motivating factor," and here, the inferences plaintiff attempts to draw
from her proffered evidence are too attenuated to survive summary
judgment when considered individually or together.