Kimberly Wheeler v. Miami Valley Career Tech. Center, 22-3315

Plaintiff Kimberly Wheeler, a long‑time teacher at Miami Valley Career Technology Center (MVCTC), applied in 2018 for three administrative posts (academic supervisor, health & consumer sciences, building principal) but was not hired for any.
Wheeler had filed an earlier discrimination/EEOC complaint and lawsuit against MVCTC in December 2012 after a prior non‑selection; that litigation concluded in January 2017.
Wheeler sued MVCTC alleging retaliation under Title VII and the Ohio Civil Rights Act, claiming the 2012 complaint led to the 2018 hiring decisions.
The district court granted summary judgment for MVCTC, finding Wheeler failed to show a causal connection between the 2012 protected activity and the 2018 adverse actions.
On appeal, the Sixth Circuit reviewed summary judgment de novo and considered whether Wheeler established a prima facie retaliation claim and, if so, whether MVCTC’s stated nondiscriminatory reasons were pretextual.
The court affirmed: temporal gap plus lack of other evidence of retaliatory conduct meant Wheeler failed to prove but‑for causation; MVCTC also proffered legitimate reasons (successful candidates were more qualified) and Wheeler offered no pretext evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Causation for prima facie retaliation	Wheeler: 2012 complaint (and subsequent litigation ending 2017) caused MVCTC to not hire her in 2018	MVCTC: the protected activity was too remote in time; no other evidence of retaliation	Held: No causal link — temporal gap is too great and insufficient supplemental evidence to show but‑for causation
Pretext and legitimate reason	Wheeler: MVCTC favored internal candidates and decisionmakers from prior suit poisoned her applications	MVCTC: successful candidates were more qualified; interviews show no animus	Held: MVCTC offered legitimate, nondiscriminatory reasons; Wheeler produced no evidence showing those reasons were pretextual

McDonnell‑Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for circumstantial discrimination/retaliation)
Univ. of Texas S.W. Med. Ctr. v. Nassar, 570 U.S. 338 (retaliation requires but‑for causation)
Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268 (temporal proximity must be very close; 20 months insufficient alone)
Vereecke v. Huron Valley Sch. Dist., 609 F.3d 392 (6th Cir.) (longer time lapse requires additional evidence to infer causation)
Imwalle v. Reliance Med. Prods., Inc., 515 F.3d 531 (6th Cir.) (periods longer than a few months undermine an inference of causation)
Provenzano v. LCI Holdings, Inc., 663 F.3d 806 (6th Cir.) (examples of evidence necessary to show pretext)