Civil Rights Lawsuit for Daycare Closing

McBeth v. Himes (CA10) (here) is probably a must-read for those of you who do retaliation cases.  I'm going to need to sit down with it.  Here's what you'll have to look forward to:

While we do not hold that the Hartman rule is applicable to “ordinary” retaliation claims, we do think that the logic of the rule necessitates its application here, where “multi-layered causation” complicates the court’s inquiry into whether the defendant’s retaliatory animus caused the adverse action that harmed the plaintiff.
In McBeth, a daycare worker had to close down operations after her license was suspended.  Why was her daycare license suspended?  Well, that's the issue.  The plaintiff claimed that her license was suspended in retaliation for her lawyering up when police asked for her clients' names and addresses.

Good luck proving retaliation where there is "multi-layered causation."  The cynical among us would call "multi-layered causation" diffusion of responsibility.  If you want to avoid a retaliation lawsuit, just convince someone else to assist with your dirty work.  Involving everyone means no one will be held responsible.  Pretty cool, isn't it?