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Keywords

discrimination
discrimination

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Thompson v. North America Stainless, LP

Facts

In February 2003, the Equal Employment Opportunity Commission (EEOC) notified the employer that the fiancee had filed a charge alleging sex discrimination. Three weeks later, the employer fired the employee. The Sixth Circuit reasoned that because the employee did not engage in any statutorily protected activity, either on his own behalf or on behalf of his fiancee, he was not included in the class of persons for whom Congress created a retaliation cause of action.

In February 2003, the Equal Employment Opportunity Commission (EEOC) notified the employer that the fiancee had filed a charge alleging sex discrimination. Three weeks later, the employer fired the employee. The Sixth Circuit reasoned that because the employee did not engage in any statutorily protected activity, either on his own behalf or on behalf of his fiancee, he was not included in the class of persons for whom Congress created a retaliation cause of action.

Issue

Did NAS's firing of Thompson constitute unlawful retaliation, and if it did, does Title VII grant Thompson a cause of action?

Did NAS's firing of Thompson constitute unlawful retaliation, and if it did, does Title VII grant Thompson a cause of action?

Rule

Title VII's antiretaliation provision must be construed to cover a broad range of employer conduct, prohibiting any employer action that 'well might have dissuaded a reasonable worker from making or supporting a charge of discrimination.'

Title VII's antiretaliation provision must be construed to cover a broad range of employer conduct, prohibiting any employer action that 'well might have dissuaded a reasonable worker from making or supporting a charge of discrimination.'

Analysis

The Court concluded that if the facts alleged by Thompson are true, then NAS's firing of Thompson violated Title VII. The Court emphasized that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired. The Court declined to adopt a categorical rule that third-party reprisals do not violate Title VII, asserting that the antiretaliation provision is worded broadly and should not be limited to specific relationships.

The Court concluded that if the facts alleged by Thompson are true, then NAS's firing of Thompson violated Title VII. The Court emphasized that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired.

Conclusion

The judgment of the Sixth Circuit was reversed, and the case was remanded for further proceedings consistent with the opinion.

The judgment of the Sixth Circuit was reversed, and the case was remanded for further proceedings consistent with the opinion.

Who won?

Thompson prevailed in the case because the Supreme Court found that he fell within the zone of interests protected by Title VII, allowing him to sue for retaliation.

Thompson prevailed in the case because the Supreme Court found that he fell within the zone of interests protected by Title VII, allowing him to sue for retaliation.

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