Law School Case Brief
Thompson v. N. Am. Stainless, LP - 562 U.S. 170, 131 S. Ct. 863 (2011)
The significance of any given act of retaliation will often depend upon the particular circumstances. Given the broad statutory text and the variety of workplace contexts in which retaliation may occur, Title VII's antiretaliation provision is simply not reducible to a comprehensive set of clear rules. However, the provision's standard for judging harm must be objective, so as to avoid the uncertainties and unfair discrepancies that can plague a judicial effort to determine a plaintiff's unusual subjective feelings.
Plaintiff employee, Eric Thompson, sued defendant employer, North American Stainless, LP under 42 U.S.C.S. § 2000e-3 of Title VII of the Civil Rights Act, claiming that Stainless had fired him to retaliate against his fiancee, also an employee, for filing a sex discrimination charge. The district court granted summary judgment to Stainless on the ground that third-party retaliation claims were not permitted by Title VII, which the Court of Appeals for the Sixth Circuit. Plaintiff sought certiorari review.
Does the claim of plaintiff employee fall under Title VII of the Civil Rights Act?
The Unitd States Supreme Court held that if the facts alleged by Thompson, the fired employee, were true, then the employer's firing of him violated Title VII because Title VII's antiretaliation provision had to be construed to cover a broad range of employer misconduct. The Court declined to adopt a categorical rule that third-party reprisals do not violate Title VII or to identify a fixed class of relationships for which third-party reprisals are unlawful. The court noted that the plaintiff could sue because he fell within the zone of interests protected by Title VII.
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