Templeton v. First Tennessee Bank, N.A., 424 F. App'x 249

Templeton, a former employee, brought Title VII retaliation and state-law claims against First Tennessee Bank and Metlife Bank after resigning following alleged harassment.
The district court dismissed Templeton’s retaliation claims as untimely, concluding too much time had passed between her protected activity and the non-rehire decision.
Templeton alleged she was retaliated against when defendants refused to rehire her about two years after resignation, plausibly linking the action to her harassment complaint.
The court reviews a Rule 12 motion de novo, treating all factual allegations as true and requiring plausibility, not mere possibility.
The panel held that, given Templeton resigned in part due to harassment and defendants cited “issues with management,” the alleged causal link was plausible at the pleading stage.
The court vacated the district court’s dismissal of the retaliation claims and remanded for further proceedings, while affirming the rest of the district court’s order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the retaliation claim was time-barred.	Templeton argues timely link between complaint and denial of rehiring.	Defendants contend too much time elapsed to establish causation.	Remanded on retaliation timing issue; not time-barred as pleaded.
Whether temporal proximity is required to establish causation in retaliation claims.	Causation can be shown by first opportunity to retaliate after complaint.	Temporal proximity alone is insufficient to infer causation.	Plausible causal link found; remanded for further proceedings.

Price v. Thompson, 380 F.3d 209 (4th Cir. 2004) (assumes retaliation in failure-to-hire context can be inferred from first opportunity)
Lettieri v. Equant, Inc., 478 F.3d 640 (4th Cir. 2007) (intervening retaliatory animus can establish causation even without proximate timing)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (Supreme Court, 2002) (pleading need not include prima facie case; must plead facts to state a claim)
Twombly, 550 U.S. 544 (Supreme Court, 2007) (requires plausibility beyond mere possibility)
Erickson v. Pardus, 551 U.S. 89 (Supreme Court, 2007) (plaintiff's allegations accepted as true on motion to dismiss)
Jordan v. Alternative Res. Corp., 458 F.3d 332 (4th Cir. 2006) (reiterates pleading element requirements for retaliation claims)
Dixon v. Gonzales, 481 F.3d 324 (6th Cir. 2007) (discusses causation beyond temporal proximity in reinstatement context)
McGuire v. City of Springfield, Ill., 280 F.3d 794 (7th Cir. 2002) (long delays do not automatically negate causation; context matters)