Yesterday, the U.S. Supreme Court effectively broadened Title VII’s anti-retaliation provision by differentiating it from Title VII’s anti-discrimination provision.  Whereas the anti-discrimination provision prohibits employers from affecting employees’ “terms and conditions” of employment, the Court held that the anti-retaliation provision is broader in scope.  Specifically, the Court stated that the anti-retaliation provision’s purpose is to protect employees from any type of employer action, whether at work or outside of work, which is intended to dissuade an employee from asserting his or her right to be free from discrimination.  Thus, the Court ruled that an employee in a Title VII retaliation action only “must show that a reasonable employee would have found the challenged action materially adverse.”