In University of Texas Southwestern Medical Center v. Nassar,133 S. Ct. 2517 (U.S. 2013) (No. 12-484), the U.S. Supreme Court held, in a 5-4 decision, that Title VII retaliation claims must be proved in accordance with traditional principles of but-for causation. In so holding, the Court distinguished Title VII retaliation claims, brought under 42 U.S.C. § 2000e-3(a), from so-called status-based discrimination claims (i.e., claims alleging discrimination based upon a person’s race, color, religion, sex or national origin) brought under a different section of Title VII, 42 U.S.C. § 2000e-2(a). The Court held that while status-based discrimination claims are subject to a lessened causation standard, which requires only proof that discrimination was a motivating factor in the employment action, plaintiffs alleging retaliation claims must show that the harm would not have occurred but for defendant’s discriminatory conduct. The Court reasoned that the language giving rise to the lesser, motivating-factor causation standard is found only in the portion of Title VII addressing status-based claims, and not in the statute’s anti-retaliation provisions. Finding that this placement was intentional, the Court concluded that Congress intended to limit the lesser causation standard to status-based claims. The Court added that its holding was supported by public policy, inasmuch as lessening the causation standard for increasingly popular retaliation claims could contribute to the filing of frivolous claims that may siphon resources away from the efforts of courts and agencies to combat workplace harassment.