Page:Veronica Ollier v. Sweetwater Union High School District (September 19, 2014) US Court of Appeals for the Ninth Circuit.djvu/42

 argue—that the district court’s adverse action findings do not satisfy this standard. The district court found that Plaintiffs’ “successful softball program was significantly disrupted to the detriment of the program and participants” because: (1) Coach Martinez was fired and replaced by a “far less experienced coach”; (2) the team was stripped of its assistant coaches; (3) the team’s annual award banquet was canceled in 2007; (4) parents were prohibited from volunteering with the team; and (5) the team was not allowed to participate in a Las Vegas tournament attended by college recruiters. It was not clear error for the district court to conclude that a reasonable person could have found any of these actions “materially adverse” such that they “well might have dissuaded [him] from making or supporting a charge of discrimination.” Id. (internal quotation marks omitted).

We construe the causal link element of the retaliation framework “broadly”; a plaintiff “merely has to prove that the protected activity and the [adverse] action are not completely unrelated.” Id. (internal quotation marks omitted). In Title VII cases, causation “may be inferred from circumstantial evidence, such as the [defendant’s] knowledge that the plaintiff engaged in protected activities and the proximity in time between the protected action and the allegedly retaliatory” conduct. Yartzoff v. Thomas, 809 F.2d 1371, 1376 (9th Cir. 1987). Emeldi extended that rule to Title IX cases. See 698 F.3d at 726 (“[T]he proximity in time