Brown v. Mark

How later courts described this case

• listed only as a one-line entry reading "Affirmed" in an Unreported Decision section of that volume of the Federal Reporter 2d
• three-month separation between protected activity and termination did not raise the inference necessary to support a prima facie case of retaliation
• "This court agrees with the utility of such an inference, but would hesitate to expand its scope ... where there are no other indicia of retaliation."

Written by the judges who cited it.