"But for" standard applies to retaliation claims

The Supreme Court has decided retaliation claims under Title VII require proof of "but for" causation establishing a confusing reality for trial judges and jurors making factual findings in cases involving discrimination claims and retaliation claims. Its confusing enough for attorneys. Now a finding of discrimination must be supported by the conclusion discrimination was a "motivating factor" while a finding of retaliation must be supported by a finding it was the "but for" cause for the adverse action.