Thompson v. North Am. Stainless, LP, 562 U.S. ___, 131 S. Ct. 863 (2011)

Eric Thompson and his fiancée, Miriam Regalado, were both employees of North American Stainless (“NAS”). Three weeks after Regalado filed a charge with the EEOC against NAS, alleging sex discrimination, NAS fired Thompson. Thompson subsequently filed a lawsuit against NAS, claiming the company had fired him in order to retaliate against Regalado for filing her charge with the EEOC. The district court dismissed Thompson’s claim on the ground that Title VII “does not permit third party retaliation claims.” The Sixth Circuit Court of Appeals affirmed the dismissal. The United States Supreme Court reversed the Sixth Circuit, finding it “obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiancé would be fired.” Compare Munoz v. Mabus, 630 F.3d 856 (9th Cir. 2010) (naval employee failed to establish that denial of training was in retaliation for his having filed age and race discrimination claims against the Navy).