Page:Taylor-Travis v. Jackson State University (17-60856) (2021) Opinion.pdf/18

 While the second paragraph states that Taylor can only prevail if she was terminated “solely as a consequence of complaints alleging noncompliance with the substantive provisions of Title IX,” that statement must be read in context of the entire paragraph. The role of the second paragraph was not to modify the requisite causal connection between Taylor’s protected activity and her termination—a topic addressed in paragraphs one and three—but to explain Lowrey’s holding that a Title IX retaliation claim cannot be based on Title VII-related “complaints related to [Taylor’s] own individual employment.” Accordingly, the statement that Taylor can only prevail if she was terminated “solely as a consequence of complaints alleging noncompliance with the substantive provisions of Title IX” should be read as distinguishing complaints about noncompliance with Title IX from “complaints related to [Taylor’s] own individual employment,” not as establishing a causation standard. Consequently, while the district court’s instruction is not a model of clarity, it did not impose a heightened causation standard. Denying Taylor’s proposed jury instruction was not an abuse of discretion or grounds for a new trial.

For the foregoing reasons, we AFFIRM the district court’s judgment regarding the breach of contract claim and the Title IX retaliation claim. We REVERSE the district court’s judgment on Taylor’s invasion of privacy claim and REMAND to the district court with instructions to enter judgment in favor of Jackson State on that claim.