News & Analysis as of

Equal Employment Opportunity Commission (EEOC) Title VII Employer Liability Issues

Proskauer - Law and the Workplace

Sixth Circuit Departs from EEOC and Other Circuits on Employer Liability Standard for Third-Party Harassment

On August 8, 2025, a Sixth Circuit panel in Bivens v. Zep, Inc. held that an employer can only be found liable under Title VII for harassment by a third party if the employer intended for the harassment to occur. This...more

Constangy, Brooks, Smith & Prophete, LLP

When is an employer liable for harassment by customers? You may be relieved.

When is an employer legally responsible for harassment of its employee by one of its customers? A recent court decision may be a relief for employers in Kentucky, Michigan, Ohio, and Tennessee. Most courts ruling on the...more

Bradley Arant Boult Cummings LLP

If You See Something, Do You Fix It If It Isn’t Your Employee? 6th Circuit Applies Higher Standard to Non-Employee Harassment Case

An employee tells you a customer just harassed them — what should you do? In Bivens v. Zep, Inc. the Sixth Circuit Court of Appeals charts its own course in addressing employer liability for third-party harassment. The Equal...more

Keating Muething & Klekamp PLL

No Intent, No Liability: Sixth Circuit Narrows Employer Liability for Third-Party Harassment

Most employers understand their obligation to prevent discrimination and harassment at work, and the significant consequences that can come if such treatment is allowed to occur. But what if an employee alleges harassment not...more

Littler

Sixth Circuit Limits Employer Liability for Harassment by Nonemployees

Littler on

On August 8, 2025, the U.S. Court of Appeals for the Sixth Circuit ruled an employer is not liable for harassment of an employee by a third party unless the employer intended for the harassment to occur. This stark departure...more

Oppenheimer Investigations Group

Workplace Investigations in Litigation: Strategic Value for Both Plaintiffs and Defendants

Workplace investigations are generally conducted outside of a litigation context and involve complaints that are not ultimately litigated. However, inevitably some workplace disputes that are investigated do make it to...more

Dickinson Wright

Sixth Circuit Raises Bar for Employer Liability for Customer Harassment of Employees

Dickinson Wright on

In Bivens v. ZEP, Inc., the Sixth Circuit held that an employer is not liable under Title VII of the Civil Rights Act of 1964, as amended (Title VII), for harassment by a customer unless the employer intended the harassment...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Did the Employer Intend for the Customer to Harass Its Employee? The Sixth Circuit Sets a High Bar

The U.S. Court of Appeals for the Sixth Circuit recently held that an employer will be liable for a customer’s harassment of an employee only when it intends for such harassment to occur. ...more

Jaburg Wilk

When Is a Company Your Employer? Understanding the Integrated Enterprise Doctrine Under Title VII

Jaburg Wilk on

Filing a charge of employment discrimination with the Equal Employment Opportunity Commission (EEOC) can be confusing when determining who the employer is. That’s especially true in a complex corporate environment, where...more

Benesch

Sixth Circuit Raises Standard for Employer Liability in Customer Harassment Cases

Benesch on

When is an employer liable for the harassment of an employee by a non-employee? The Sixth Circuit answered this question on Friday in Bivens v. Zep, Inc., holding that Title VII imposes liability for customer (or other...more

FordHarrison

Sixth Circuit Requires Proof of Intent for Employers to be Liable for Harassment by a Nonemployee

FordHarrison on

On August 8, 2025, in Bivens v. Zep, Inc., the United States Court of Appeals for the Sixth Circuit held that employer liability for nonemployee harassment requires proof of the employer’s intent, a departure from the...more

Perkins Coie

DOJ’s DEI Federal Fund Recipient Guidance Deserves Attention by Private Sector Employers

Perkins Coie on

Key Takeaways - - A recently released memo from the U.S. attorney general reminds employers of the current administration’s stance on diversity, equity, and inclusion efforts. - The guidance is explicitly directed at...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Federal Religious Expression and Accommodations Guidance May Impact Private Employers

In July 2025, the U.S. Office of Personnel Management (OPM) issued two important memos regarding religious accommodations and religious expression in federal workplaces. ...more

Husch Blackwell LLP

Proselytizing Online, Fired in Real Life: Are Anti-LGBTQ+ Views Protected by Title VII?

Husch Blackwell LLP on

Earlier this month, the Equal Employment Opportunity Commission (EEOC), after first attempting to reach a pre-litigation settlement, commenced litigation against Rock Snowpark on July 2, 2025, for allegedly retaliating...more

Conn Maciel Carey LLP

Ames v. Ohio Department of Youth Services: What the Supreme Court’s Unanimous Ruling Means for Employers and DEI Policies

Conn Maciel Carey LLP on

Reshaping the litigation landscape for workplace discrimination claims, last month, the U.S. Supreme Court ruled in Ames v. Ohio Dept. of Youth Servs., 145 S. Ct. 1540 (June 5, 2025), that plaintiffs bringing so-called...more

Bradley Arant Boult Cummings LLP

Yes, Menstrual Cramps May Qualify as a Disability Under ADA

If a qualified job candidate asks to reschedule a second-round interview due to severe menstrual cramps associated with endometriosis, is that a request for an accommodation under the Americans with Disabilities Act? If you...more

Berkshire

Private Plaintiff Attorneys Step Up in Title VII Disparate Impact Cases

Berkshire on

After the White House announced that it would “deprioritize” disparate impact cases, many employers may have mistakenly concluded that disparate impact liability was no longer a concern under Title VII. However, recent...more

Brooks Pierce

High Court Unanimously Rejects the Imposition of Special Requirements for “Majority Group” Discrimination Claims

Brooks Pierce on

On Thursday, June 5, 2025, the Supreme Court unanimously rejected the notion that Title VII of the Civil Rights Act of 1964 (“Title VII”) imposes special requirements on a “majority-group” plaintiff trying to make an initial...more

Jackson Lewis P.C.

What Do Recent DEI Training-Focused Federal Agency Guidance and Court Decisions Mean for Employers?

Jackson Lewis P.C. on

Two new technical-assistance documents jointly released by the Equal Employment Opportunity Commission (EEOC) and Department of Justice (DOJ) warn that common diversity, equity, and inclusion (DEI)-training practices —...more

Fisher Phillips

SCOTUS Scraps Extra Hurdle in Majority-Group Bias Claims: 5 Ways That Things Will Change for Employers

Fisher Phillips on

The US Supreme Court just unanimously ruled that plaintiffs alleging workplace discrimination under Title VII are not required to meet a heightened evidentiary standard just because they have “majority-group” status....more

Fisher Phillips

Workplace Law Update: 10 Essential Items on Your June To-Do List

Fisher Phillips on

Here are the top items you should tackle in June, based on the latest workplace law developments and upcoming critical compliance dates...more

Venable LLP

New Trump Executive Order Dismantles Disparate Impact Liability

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On April 23, President Trump issued an executive order, "Restoring Equality of Opportunity and Meritocracy" (EO), intending to abolish a longstanding liability theory for workplace discrimination claims. Emphasizing the need...more

Lathrop GPM

Executive Order Shifts Federal Enforcement Away from Disparate Impact Theory of Discrimination Liability

Lathrop GPM on

An Executive Order signed by President Trump on April 23, titled “Restoring Equality of Opportunity and Meritocracy,” directs federal agencies to shift their enforcement of civil rights laws away from disparate impact...more

Lathrop GPM

Federal Agencies Issue Guidance Identifying DEI Policies and Practices That May Be Unlawful

Lathrop GPM on

Last month, the Equal Employment Opportunity Commission (EEOC) and Department of Justice (DOJ) issued guidance that aims to educate the public about conduct and programs related to diversity, equity and inclusion (DEI)...more

Fox Rothschild LLP

Trump Executive Order Rolls Back Disparate-Impact Enforcement

Fox Rothschild LLP on

President Trump has issued an executive order aimed at significantly reducing the use of disparate-impact analysis by federal agencies when enforcing anti-discrimination laws. Titled “Restoring Equality of Opportunity and...more

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