Footnote 243

See id. at 1671 ("When liability depends on proof of a particular bad reason for discharge, 'no reason' or even a demonstrably false or fabricated reason is good enough for the employer to escape liability."); McGinley, Cronyism, supra note 38, at 1022. But cf. Fernandes v. Costa Bros. Masonry, Inc., 199 F.3d 572, 587 (1st Cir. 1999) ("[A] court, at the summary judgment stage, may [not] accept uncritically an employer's articulation of cronyism as an explanation for its actions.").