A factual or legal relationship between conduct and a resulting injury or consequence that must be shown to establish liability, standing, or admissibility of evidence.
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Common Examples
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Burden Shift in Alternative Liability
Cade Carpenter and Corinne Cho each negligently stored chemicals near a shared worksite. A worker suffered severe burns from an explosion traced to one of the storage areas, but no evidence identified which defendant's negligence triggered the blast. The court shifted the burden to each defendant to prove his storage practices did not cause the injury.
Year-and-a-Day Limit on Homicide
Charles Cunningham stabbed a victim during a fight. The victim lingered for fourteen months before dying from complications. Prosecutors could not charge homicide even though the wound clearly started the chain of events leading to death.
Camila Cervantes sued two contractors after a building collapse injured her. The contractors disputed whether their respective work on separate support beams contributed to the failure. The judge ruled that the evidence created no jury question on whether either contractor's conduct was a substantial factor in the collapse.
Intent Requirement for Forfeiture
Christine Castro intimidated a witness into leaving the state before trial. The witness later refused to testify. The prosecution could not introduce the witness's prior statement because it failed to prove Castro acted with the specific purpose of preventing testimony.
Physician Decision in Warning Cases
Cynthia Cortez sued a medical device maker after suffering complications from an implant. She showed the device carried undisclosed risks but offered no evidence that a better warning would have changed her physician's decision to prescribe it. The court entered judgment for the manufacturer.
No Link to Business Activity
Continental Bank challenged a state minimum-wage law requiring higher pay for women workers. The statute imposed the wage floor based solely on workers' living needs rather than any connection to the value of services performed for the bank. The Court struck down the law.
West Coast Hotel Co. v. Parrish300 U.S. 379 (1937)
In 1913 the State of Washington enacted a statute entitled An Act to establish a minimum wage for women and minors. The law created an Industrial Welfare Commission. A later statute transferred its duties to an Industrial Welfare Committee consisting of the Director of Labor and Industries, the Supervisor of Industrial Insurance, the Supervisor of Industrial Relations, the Industrial Statistician and the Supervisor of Women in Industry.
The statute required the commission to investigate wages and conditions of labor for women and minors. It required public hearings. When wages were found inadequate to supply the necessary cost of living and maintain workers in health, the commission was to convene conferences of employers, employees and public representatives before issuing obligatory orders fixing minimum wages. Special licenses were authorized for physically defective or apprentice workers at lower rates. The statute had remained in force for more than twenty-three years by the time of the present litigation.
Elsie Parrish was employed by the West Coast Hotel Company as a chambermaid. She and her husband brought suit against the company to recover the difference between the wages actually paid and the minimum wage. The minimum wage was $14.50 per week of 48 hours fixed by the Industrial Welfare Committee pursuant to the statute. The company had paid her less than the prescribed minimum during her employment.
The Supreme Court of Washington reversed the trial court judgment, sustained the statute, and directed entry of judgment for the plaintiffs.
The West Coast Hotel Company appealed to the United States Supreme Court. The appeal brought before the Court the question of the constitutional validity of the Washington minimum wage statute. The Washington law was substantially identical to minimum wage statutes enacted in Oregon in the same year. Similar laws had been adopted in the District of Columbia in 1918 and in other states during the same period.
What evidence shows a causal connection in an employment retaliation claim?
A plaintiff must prove the protected activity was a but-for cause of the adverse action. Courts accept direct statements, patterns of negative treatment after complaints, false reasons given by the employer, increased scrutiny, or close temporal proximity between the activity and the action.
Does mere temporal proximity always establish causation in retaliation cases?
No. While close timing can support an inference, courts examine whether the employer knew of the protected activity and whether other evidence shows the timing was not coincidental. Longer gaps weaken the inference unless accompanied by other indicators of retaliation.
When does the year-and-a-day rule bar homicide liability?
The rule bars liability if the victim dies more than a year and a day after the injury. Even clear but-for causation is insufficient once the period expires.
What must the government prove for forfeiture by wrongdoing to apply?
The government must show the defendant engaged in conduct designed to prevent the witness from testifying. Mere causation of unavailability without that intent is insufficient.
418 U.S. 323, 94 S. Ct. 2997, 41 L. Ed. 2d 789 (1974)
…conduct of the recipients toward the plaintiff and because the recipients, the only witnesses able to establish the necessary causal connection, may be reluctant to testify that the publication affected their relationships with the plaintiff. Thus some presumptions are necessary if the plaintiff is to be adequately compensated."…