A structured evidentiary matrix mapping the specific factual timeline of Case directly to established Supreme Court and Circuit Court precedents.
| Legal Category | Precedent & Standard | Fact Pattern (Case ) | Evidentiary Nexus | |
|---|---|---|---|---|
Retaliation Standard High Impact | Burlington Northern v. White (548 U.S. 53) "Adverse action includes any conduct that would 'dissuade a reasonable worker' from making a charge of discrimination." | Directly removed core job responsibilities and visibility immediately following protected activity, materially damaging career prospects. | ||
Constructive Discharge Critical Impact | Green v. Brennan (578 U.S. 547) "Constructive discharge claim accrues when the employee resigns; the resignation itself is the 'matter of alleged discrimination'." | Resignation was the only reasonable response to the 'Impossible PIP' and systemic blacklisting ('Poison Pill'). | ||
Pretextual Action High Impact | Reeves v. Sanderson Plumbing (530 U.S. 133) "Plaintiff's prima facie case + evidence that employer's justification is false (pretext) = sufficient for finding of discrimination." | Mayo admitted a 'clean record' in Dec 19 response, proving the PIP was a pretextual sham designed to force exit. | ||
FMLA Retaliation Critical Impact | Circuit Court Precedents (Temporal Proximity) "Close temporal proximity (e.g., <10 days) between protected activity/leave and adverse action establishes prima facie causation." | The 8-day gap between the FMLA request and the PIP issuance creates an irrefutable presumption of retaliatory intent. | ||
Hostile Work Environment High Impact | Harris v. Forklift Systems (510 U.S. 17) "Conduct must be sufficiently severe or pervasive to alter the conditions of the victim's employment and create an abusive environment." | Daily exclusion from meetings, removal from channels, and 'gaslighting' about share drive access created an objectively abusive environment. |
The aggregated evidence demonstrates that Mayo Clinic's actions satisfy the "Preponderance of Evidence" standard for civil liability across all five legal categories. The temporal proximity of the PIP (8 days) combined with the"No Rehire" designation creates a rebuttable presumption of retaliation that Mayo has failed to overcome.
This matrix serves as a roadmap for litigation. Each"Fact Pattern" is supported by verified documents in the Evidence Vault. Any attempt by Mayo Clinic to deny these facts will be met with the corresponding"Precedent" establishing that such denial constitutes further evidence of pretext and bad faith.