context: . In any event, Corning likely makes out a prima facie case because viewing the facts in the light most favorable to him, (1) he engaged in protected activity when he requested an accommodation including to not work out of the storage shed; (2) he suffered an adverse employment action when LodgeNet terminated him; and (3) given that there were only two days between the request and his termination, Corning shows that the adverse action was causally related to the protected conduct.
citation_a.signal: see
citation_a.identifier: 197 F.3d 1337, 1337
citation_a.parenthetical: "[A] plaintiff satisfies [the causal connection] element if he provides sufficient evidence that the decision-maker became aware of the protected conduct, and that there was close temporal proximity between this awareness and the adverse employment action."
citation_a.sentence: See Farley, 197 F.3d at 1337 ("[A] plaintiff satisfies [the causal connection] element if he provides sufficient evidence that the decision-maker became aware of the protected conduct, and that there was close temporal proximity between this awareness and the adverse employment action.”); Reis, 442 F.Supp.2d at 1254 (same); but see Jenks, 829 F.Supp.2d at 1254 ("Close temporal proximity between the protected conduct and the adverse employment action is generally sufficient circumstantial evidence to create a genuine issue of material fact as to the causal connection, however this alone may not be sufficient to establish pretext.”).
citation_b.signal: but see
citation_b.identifier: 829 F.Supp.2d 1254, 1254
citation_b.parenthetical: "Close temporal proximity between the protected conduct and the adverse employment action is generally sufficient circumstantial evidence to create a genuine issue of material fact as to the causal connection, however this alone may not be sufficient to establish pretext."
citation_b.sentence: See Farley, 197 F.3d at 1337 ("[A] plaintiff satisfies [the causal connection] element if he provides sufficient evidence that the decision-maker became aware of the protected conduct, and that there was close temporal proximity between this awareness and the adverse employment action.”); Reis, 442 F.Supp.2d at 1254 (same); but see Jenks, 829 F.Supp.2d at 1254 ("Close temporal proximity between the protected conduct and the adverse employment action is generally sufficient circumstantial evidence to create a genuine issue of material fact as to the causal connection, however this alone may not be sufficient to establish pretext.”).