20 Whitman, 293 Mich App at 232, n 1. 21 Id. at 230. 22 Whitman, 493 Mich at 309. 23 Id. 24 It is difficult to see how a statement the mayor allegedly made after he had already declined to reappoint plaintiff would influence his decision not to reappoint him. 25 See, for example, West v Gen Motors Corp, 469 Mich 177, 186; 665 NW2d 468 (2003) (to satisfy causation requirement under the WPA, a plaintiff must show “something more than merely a coincidence in time between protected activity and adverse employment action”); Tuttle v Metro Gov’t of Nashville & Davidson Co, Venn, 474 F3d 307, 321 (CA 6, 2007) (“[t]he law is clear that temporal proximity, standing alone, is insufficient to establish a causal connection for a retaliation claim”); Shaw v Ecorse, 283 35; 630 NW2d 46 (2001) (<HOLDING>). 27 Burton Ordinances 6.2(b) states that the
holding that a sixmonth gap between the protected activity and the employees termination was insufficient to infer that the protected activity was a contributing factor 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 a lengthy delay of approximately a year between plaintiffs reports and her termination does not support an inference she was fired because of the protected activity holding that a 17 month time period between the employees protected speech and his termination could not support an inference of causation holding that a threeyear gap between the protected activity and the adverse employment action was insufficient to support an inference of causation