In University of Texas Southwestern Medical Center v. Nassar (June 24, 2013), the Supreme Court ruled that in a Title VII retaliation case, a plaintiff must prove that an employer would not have taken an adverse employment action “but for” an improper motive as opposed to proving the lesser causation standard or the “mixed motive” standard, which requires a plaintiff to show that retaliation was one of the employer’s motives, even if the employer had other, lawful motives that contributed to the employer’s adverse employment decision. Based on this recent decision, Title VII retaliation claims will be much more difficult for a plaintiff to prove.