Mealey's (September 12, 2019, 12:04 PM EDT) -- NEW YORK — A former university assistant coach’s bias claims brought under 42 U.S. Code Section 1983 fail because she needed to meet, unlike claims under Title VII of the Civil Rights Act of 1964, the but-for causation standard, a Second Circuit U.S. Court of Appeals panel ruled Aug. 12, reversing a trial court’s ruling on those claims (Elizabeth Naumovski v. James Norris, et al., Nos. 18-1556 and 18-2663, 2nd Cir., 2019 U.S. App. LEXIS 23891)....