Case Explained: JEFFREY STEIDLE v. UNITED STATES LIABILITY INSURANCE CO., INC

Court: United States Court of Appeals for the Third Circuit Filed: 2026-06-24 Docket: 2:22-cv-04972) The Third Circuit vacated the District Court’s grant of summary judgment regarding Jeffrey Steidle’s retaliation claims under the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA) stemming from his 2020 bonus and salary increase, while affirming the grant of summary judgment on his retaliation claims regarding his 2021 bonus and salary increase. The court held that the “materially adverse” standard established in *Burlington Northern & Santa Fe Railway Co. v. White* for Title VII retaliation claims applies equally to ADA and FMLA retaliation claims, meaning an action is adverse if it would dissuade a reasonable worker from making or supporting a charge of discrimination. Under this standard, the court found that Steidle presented sufficient evidence that receiving significantly lower bonuses and salary increases than in previous years could constitute an adverse employment action. Furthermore, regarding causation, the court determined that the unusually suggestive temporal proximity between Steidle’s protected FMLA leave in late 2020 and the approval of his reduced 2020 compensation created a genuine issue of material fact, whereas the six-month gap between his May 2021 accommodation request and the 2021 bonus determination was insufficient to establish causation without additional evidence of antagonism. Consequently, the case is remanded to the District Court to determine in the first instance whether Steidle can establish that USLI’s proffered reasons for the 2020 compensation reductions were pretextual. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.