The Supreme Court held that the protections of Title VII of the Civil Rights Act extend to those who claim third-party retaliation.
The wife of Plaintiff filed a gender discrimination claim with the United States Equal Employment Opportunity Commission (“EEOC”) against the subsidiary of a company. Soon after, the company fired Plaintiff. Plaintiff sued for retaliation. The District Court, however, granted summary judgment for the company. The district court held that Title VII of the Civil Rights Act does not permit third-party retaliation claims. On appeal the United States Court of Appeals for the Sixth Circuit affirmed, holding that Plaintiff was not entitled to sue for retaliation since he had not engaged in any activity protected by the statute.
The Supreme Court reversed and remanded, concluding that Plaintiff’s firing stated a claim of unlawful retaliation. The Court held that the “person aggrieved” term used in Title VII incorporates the zone of interest test of the Administrative Procedure Act and that Plaintiff was a “person aggrieved” because Title VII’s purpose is to protect employees from their employers’ unlawful actions.
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