In Clark County School Dist. v. Breeden (2001) 532 U.S. 268, the plaintiff alleged that she had been harassed, and that her employer had transferred her in retaliation for filing her subsequent administrative complaint and civil action. (532 U.S. at pp. 269-270.) Her only evidence that her complaints were causally responsible for her transfer was that she had filed her administrative complaint two years before the transfer, and that she had received a right-to-file letter three months before the transfer. (Id. at pp. 272-274.) The court in Clark County School Dist. held that this evidence did not establish the causal element of a prima facie case of retaliation, reasoning that there was no evidence the decision maker who ordered the transfer knew of the right-to-sue letter or the administrative complaint, and even if the decision maker was aware of this complaint, the two-year gap between its filing and the transfer nullified the inference of a causal connection. (Ibid.)