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Analyze
Break down an opinion for use in your brief
Separates the rule from the holding from the dicta, then answers the question that decides whether you cite it: is this binding where you are filing?
Your prompt
2
Pressure-test it
3
Go deeper
Before you run it
What to gather first
Watch for
What comes back
See an example of what you’ll get
*(After you answer the four questions: you found this case and want to use it; the best thing you already hold is a Ninth Circuit decision on proximity generally, nothing squarely on a 4-day gap; your KeyCite came back clean with no negative treatment; it gets a full argument section.)*
Citation. *Yartzoff v. Thomas*, 809 F.2d 1371 (9th Cir. 1987).
Rule. Temporal proximity between protected activity and an adverse employment action can, without more, support the causation element of a Title VII retaliation claim at the prima facie stage where the proximity is close.
Holding. Where an employee's EEOC complaint was followed by reassignment within one month and demotion within roughly two and a half months, that timing satisfied the causal-connection element of the prima facie case. Id. at 1376. [UNVERIFIED - confirm before relying: check both intervals against the opinion itself before you build an a fortiori argument on them.]
Reasoning.
1. The McDonnell Douglas framework requires a causal link between protected activity and adverse action at the prima facie stage. Id. at 1375.
2. Causation may be inferred from circumstantial evidence, including the timing of the two events. Id.
3. Where the adverse action follows closely on the protected activity, that timing alone can carry the prima facie burden. Id.
4. On these facts, two adverse actions within months of the complaint cleared the threshold. Id. at 1376.
5. [my inference] The court never separates the reassignment from the demotion, so the opinion does not tell us whether one action alone would have sufficed.
Dicta. The court's observation that longer gaps would require additional evidence was unnecessary: no long gap was before it. Quotable, not binding, and the other side will read the same sentence as an implied ceiling.
Weight in D. Ariz. (Ninth Circuit). Binding. Published Ninth Circuit panel decision, no en banc treatment, majority opinion with no separate writings that narrow it. Because you told me the KeyCite came back clean, that is a conclusion rather than a caveat. Had you not run it, this line would read "binding subject to subsequent history I cannot see." Later Ninth Circuit decisions have refined how much proximity carries at summary judgment as opposed to the pleading stage [UNVERIFIED - confirm against the citator report you ran].
Application.
*How it helps.* Your 4-day gap is an order of magnitude tighter than the timing Yartzoff found sufficient. If roughly two and a half months supported the inference there, four days does so a fortiori, and the absence of documented prior discipline removes the intervening-cause explanation the employer would otherwise offer.
*The distinction, at full strength.* BetaCorp will argue Yartzoff rested on a pattern (reassignment followed by demotion), not on a single event, and that the court's own reasoning at 1376 treats the sequence as the circumstantial evidence. It will then argue you are at summary judgment, not the pleading stage, where the Ninth Circuit has required more than timing once the employer articulates a legitimate reason; and it will point to Reyes's two missed February deadlines as exactly that reason, arguing the four-day gap is coincidence with a documented performance predicate. That is a real argument, not a throwaway.
Bottom line. Moderate at opposing summary judgment: strong on the prima facie element, weaker once the burden shifts, and Yartzoff does not reach pretext. It would move to strong if paired with a Ninth Circuit case applying proximity at the pretext stage, or if the February deadline issue turns out to be undocumented.
Assumptions. I read your facts as putting the missed deadlines before the protected activity [ASSUMPTION - verify; if they postdate March 3, the pretext analysis changes entirely].
What your answers changed. The clean citator run is what let me state the weight as a conclusion; with "not run yet" the entire weight section would have been a caveat and the bottom line would have dropped to weak. That you hold nothing closer than a general proximity case is why this one earns a full section. If you already had a Ninth Circuit decision applying proximity at the pretext stage, my advice would have been to cite this one in a parenthetical and move on. Your answer that you found the case and want to use it changed only the order of the two application paragraphs, not the analysis; if that was the only thing you were unsure about, you did not need to be asked.
Why this prompt is built the way it is
## Framework
1. **Rule and holding are different sentences.** The rule is what the case stands for going forward. The holding is fact-bound and answers what this court decided about these parties.
2. **Reasoning is a chain, not a summary.** Premise, premise, conclusion, each with a pin cite. Inference that is yours rather than the court's gets labeled.
3. **Dicta is anything broader than the judgment required**: useful, quotable, and not binding. Say why it was unnecessary.
4. **Weight before worth.** Binding, persuasive, or neither in the filing court. Published or not, panel or en banc, majority or plurality, and whether a concurrence narrows the majority.
5. **Steelman the distinction.** Write the other side's distinction as they would write it, not as a straw man.
6. **Stage matters.** A case clearing a prima facie threshold proves nothing at trial.
7. **Never reconstruct a citation from memory.** Anything not in the input gets marked, not supplied.