Aisha Putnam v. Caramelcrisp, LLC

Summary

The court dismissed Putnam's trial-related appellate challenges because she failed to provide complete trial transcripts needed to assess prejudice, and it affirmed the rulings disposing of her claims. It held that an FSMA retaliation plaintiff must prove protected activity, employer knowledge, an unfavorable personnel action, and that the protected activity was a contributing factor, but Putnam offered no evidence that a responsible decisionmaker knew of her FDA emails. The court also upheld refusal to allow a new retaliation theory based on the trade-secrets lawsuit and declined to revive the Illinois common-law claim because the jury had already rejected causation under the less demanding FSMA standard.