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Rust v. Carondelet Health Care & Health Network

Citation: 168 F. App'x 241Docket: No. 05-15490

Court: Court of Appeals for the Ninth Circuit; February 21, 2006; Federal Appellate Court

Narrative Opinion Summary

Jan Rust appeals pro se from the district court's summary judgment that dismissed her retaliation claim against her former employer, Carondelet Health Network (CHN). The appellate court has jurisdiction under 28 U.S.C. § 1291 and reviews the case de novo. The court affirmed the district court's decision, determining that Rust did not establish a prima facie case of retaliation. Although a negative employment reference could constitute an adverse employment action, Rust did not provide sufficient evidence for a reasonable juror to conclude that CHN issued a negative reference about her. Other arguments raised by Rust were found to lack merit. The ruling is not suitable for publication and cannot be cited in future cases, except as allowed by 9th Cir. R. 36-3.

Legal Issues Addressed

Adverse Employment Action in Retaliation Claims

Application: The appellate court considered whether a negative employment reference could constitute an adverse employment action but found insufficient evidence to support the plaintiff's claim.

Reasoning: Although a negative employment reference could constitute an adverse employment action, Rust did not provide sufficient evidence for a reasonable juror to conclude that CHN issued a negative reference about her.

Summary Judgment under Retaliation Claims

Application: The court affirmed the summary judgment in favor of the employer, finding that the plaintiff failed to establish a prima facie case of retaliation.

Reasoning: The court affirmed the district court's decision, determining that Rust did not establish a prima facie case of retaliation.

Unpublished Opinions and Citation Restrictions

Application: The ruling is designated as not suitable for publication and cannot be cited in future cases, with exceptions as per specific court rules.

Reasoning: The ruling is not suitable for publication and cannot be cited in future cases, except as allowed by 9th Cir. R. 36-3.