view the employment action in question as adverse.” Id. at 1449. Like the Supreme Court in White, the Eleventh Circuit established an objective, reasonable person standard. Id. at 1449. Likewise, the Eleventh Circuit stressed that “[a]ny adversity must be material; it is not enough that a transfer impose[ ] some de minimis inconvenience or alteration of responsibilities.” Id. at 1453. In other words, the Eleventh Circuit subsumed a requirement of materiality within its reasonable person standard for adversity. Id. (“Thus, any ... requirements for Doe must rise to a level that a reasonable person would deem materially adverse .... ”). This Court finds no appreciable difference in applying the standard articulate by the Supreme Court in White and the standard articulate 1 (S.D.Ala.1997) (<HOLDING>). The record contains evidence of multiple
holding that more than a year between the protected activity and the discharge is not close enough to support the causal connection requirement holding that five weeks between protected activity and adverse employment action insufficient to establish a causal connection holding that a 7month time period between the protected activity and the adverse employment action is too indirect to satisfy the causal connection requirement holding that twentyfour days between protected activity and termination is sufficient to infer existence of causal connection holding that there must be a causal connection between the advertising activity and the injury alleged in the underlying complaint