To plead a prima facie case of retaliation under § 1981, a plaintiff must allege that: (1) she engaged in a statutorily protected activity; (2) she suffered an adverse employment action; and (3) there was some causal connection between the protected activity and the adverse employment action. Barr v. Bd. of Regents of Univ. Sys. of Georgia, No. 4:17-CV-203, 2019 WL 1099791, at *12 (S.D. Ga. Mar. 8, 2019) (citing Goldsmith v. Bagby Elevator Co., 513 F.3d 1261, 1277 (11th Cir. 2008)).
Congress's addition of (b) in § 1981 overturned the Supreme Court's decision in Patterson v. McLean Credit Union, which had "narrowly construed the protective reach of [§ 1981] to prohibit race discrimination 'only [in] the formation of a contract, but not [in] problems that may arise later from the conditions of continuing employment.'" Barr v. Bd. of Regents of the Univ. Sys. of Ga., No. 4:17-cv-203, 2019 WL 1099791, at *6 (S.D. Ga. Mar. 8, 2019) (second and third alterations in original) (quoting Patterson v. McLean Credit Union, 491 U.S. 164, 176 (1989)). Before this amendment, courts were to utilize the most analogous state statute of limitations with respect to § 1981 (§ 1983) claims.