Staub v. Proctor Hospital, 131 S. Ct. 1186

Staub, an angiography technician, was employed by Proctor Hospital and was fired in 2004 after mixed internal actions and investigations.
Mulally (Staub's supervisor) and Korenehuk (Mulally's supervisor) harbored hostility to Staub's Army Reserve duties and influenced scheduling and reports about him.
Mulally issued a January 2004 Corrective Action claiming Staub violated a non-existent or misapplied rule requiring him to stay near patients when not with a patient.
In April 2004, a coworker complained about Staub; Buck, Proctor’s HR VP, initiated a plan to address his alleged availability issues, relying on Korenehuk's accusation that Staub left his desk without notice.
Buck fired Staub after reviewing his file and relying on the January Corrective Action and Korenehuk's report, despite Staub claiming the accusation was false.
Staub alleged his discharge was motivated by antimilitary hostility of his supervisors, and that Buck's decision was shaped by those reports, constituting cat’s-paw liability under USERRA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a cat’s-paw liability can attach to an employer under USERRA.	Staub argues supervisors’ antimilitary animus can be aggregated to bind employer.	Proctor asserts liability requires the decisionmaker to be motivated by antimilitary animus, not merely influenced by biased reports.	Yes; employer liable if biased acts were intended to cause the adverse action and proximate to the decision.
Whether proximate cause can be established when the decisionmaker merely relied on a biased report.	Discriminatory reports can be proximate cause even if the decisionmaker had no hostile motive.	Independent decisionmaker’s own animus or independent investigation could sever the link.	The biased report can be a proximate cause; independent investigation does not automatically sever liability.
Whether the decisionmaker’s exercise of independent judgment defeats USERRA liability.	Independent judgment should not absolve liability if initial reports were discriminatory.	Independent judgment decouples the adverse action from the discriminatory motive.	Not required to immunize; discrimination remains a factor if intended to cause the action.

Burlington Northern & Santa Fe Ry. Co. v. United States, 556 U.S. 599 (U.S. 2009) (background tort-law principles apply to federal torts and intent-based liability)
Safeco Ins. Co. of America v. Burr, 551 U.S. 47 (U.S. 2007) (intent and standard of proof in tort-like claims)
Kawaauhau v. Geiger, 523 U.S. 57 (U.S. 1998) (intent required to cause consequences in intentional torts)
Anza v. Ideal Steel Supply Corp., 547 U.S. 451 (U.S. 2006) (proximate causation and tort standards in employment context)
Sosa v. Alvarez-Machain, 542 U.S. 692 (U.S. 2004) (multiple proximate causes doctrine in tort law)
Exxon Co., U.S.A. v. Sofec, Inc., 517 U.S. 830 (U.S. 1996) (foreseeability and superseding cause concepts in proximate causation)
Faragher v. Boca Raton, 524 U.S. 775 (U.S. 1998) (employer liability for supervisor-created hostile environment under tort-like framework)
Pennsylvania State Police v. Suders, 542 U.S. 129 (U.S. 2004) (grievance procedures and statutory framework for discrimination claims)