In Staub v. Proctor Hospital, U.S., 131 S.Ct. 1186, 1189, 179 L. Ed. 2d 144 (2011), the Supreme Court considered "the circumstances under which an employer may be held liable for employment discrimination based on the discriminatory animus of an employee who influenced, but did not make, the ultimate employment decision." The Court held that "if a supervisor performs an act motivated by [discriminatory] animus that is intended by the supervisor to cause an adverse employment action and if that act is a proximate cause of the ultimate employment action," then the employer may be held liable. Id. at 1194. Moreover, if a supervisor submits a biased report urging an adverse employment action, even if the decision-maker conducts an independent investigation in response to the report and concludes that termination is justified, an employee still may show that the biased report was the proximate cause of the adverse employment action if it was one of many factors considered by the decision-maker. Id. at 1193.