INTRODUCTION. On March 1, 2011, the Supreme Court issued its decision in Staub v. Proctor Hospital. Staub, a case brought under the Uniform Services Employment and Reemployment Rights Act of 1994 (USERRA), is the first U.S. Supreme Court decision addressing the "cat's paw" line of cases, that is, cases involving an adverse employment action which give the appearance that the action is being taken by a neutral party when in reality it is motivated, at least partly, by a biased supervisor.

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