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The U.S. Supreme Court has held that a coach in a school receiving federal funding may bring a private action under Title IX claiming he was subjected to retaliation for complaining about student sex discrimination. Employee claiming retaliation under state job bias statute must show that the employer's conduct caused substantial and tangible harm to the employee's job; a negative performance evaluation alone is insufficient to support such a claim. The newly-enacted federal Class Action Fairness Act is not retroactive; the new law may only be used to remove cases to Federal Court filed on or after February 18, 2005.
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