A person has standing under Title VII if their interests fall within the zone of interests protected by the statute's antiretaliation provision.
An employee sued his employer under Title VII, alleging he was fired in retaliation for his fiancée filing a sex discrimination charge. The employer argued that the employee lacked standing because he had not personally engaged in protected activity. The Court holds that Title VII's antiretaliation provision prohibits any employer action that might dissuade a reasonable worker from making or supporting a charge of discrimination. Furthermore, the term person aggrieved includes any plaintiff whose interests fall within the zone of interests sought to be protected by the statute. Because the employer's intent was to punish the fiancée by harming the employee, the employee is an aggrieved person with standing to sue.
At page 174 Determining dissuasion from protected activity by third-party reprisals38 citing cases“we think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired.”
- Whalen, Mark v. MacKenzie, Dana, 760 F. Supp. 3d 743 (W.D. Wis. 2024).published(We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired.)
- Simmons v. Alabama State Univ., No. 2:18-cv-00640 (M.D. Ala. Aug. 3, 2021). See Thompson, 562 U.S. at 178 (“[I]njuring him was the employer’s intended means of harming [her, the complaining employee].
- Tromblee v. State of New York, No. 1:19-cv-00638 (N.D.N.Y. Mar. 16, 2021). (We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her [fiancée] would be fired.)
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published “Shareholders are not within Title VII’s zone of 10 See Thompson, 562 U.S. at 178 (“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.”). 11 Sec.
- Su v. Bevins & Son, Inc., No. 2:23-cv-00560 (D. Vt. May 7, 2024).([A] reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired.)
- Sambrano v. United Airlines Inc, 707 F. Supp. 3d 652 (N.D. Tex. 2023).published“title vii's antiretaliation provision prohibits an employer from discriminating against any of his employees for engaging in protected conduct.”
- Wilson v. Connecticut Dep't of Transp., 706 F. Supp. 3d 327 (D. Conn. 2023).published See Thompson v. N. Am. Stainless, LP, 562 U.S. 170 , 175 (2011) (“We think there is no textual basis for making an exception to [the broad standard for retaliatory conduct] for third-party reprisals . . . .”).
- Purnell v. City of Philadelphia, No. 2:20-cv-03718, 2021 WL 3617161 (E.D. Pa. Aug. 16, 2021). “the antiretaliation provision, unlike the substantive provision, is not limited to discriminatory actions that affect the terms and conditions of employment.”
- Ali v. Dist. of Columbia Gov't, 810 F. Supp. 2d 78 (D.D.C. 2011).published (We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired.)
- Jones, No. 3:24-cv-00255 (N.D. Ind. Dec. 19, 2025).The pertinent inquiry is whether an employer has acted in a way that “might have dissuaded a reasonable worker from making or supporting a charge of discrimination.” Id. at 174 (citation omitted).
Show 28 more citing cases
- Rubicon Real Est. Holdings, LLC v. Pontiac, City of, 791 F. Supp. 3d 761 (E.D. Mich. 2025).published Thompson, 562 U.S. at 174, 178.
- Wilson v. Lear Corp., No. 1:23-cv-00337 (N.D. Ind. Oct. 2, 2024).The pertinent inquiry is whether an employer has acted in a way that “might have dissuaded a reasonable worker from making or supporting a charge of discrimination.” Id. at 174 (citation omitted).
- Richard Miller v. Michigan Dep't of Corr., 15 N.W.3d 129 (Mich. 2024).published The Court noted that the antidiscrimination prohibitions of Title VII were limited to actions “with respect to . . . compensation, terms, conditions, or privileges of employment,” while the antiretaliation prohibitions of Title VII covered…
- Jenai Hayes v. Metro. Gov't of Nashville, No. 23-5075 (6th Cir. Dec. 13, 2023).unpublished Thompson, 562 U.S. at 174. - 12 - Nos. 23-5027/5075, Hayes v. Metro.
- Muldrow v. Garland, No. 8:21-cv-02674 (M.D. Fla. Sept. 30, 2023).And none of these actions are like threats to fire an employee’s fiancé or threats to harm one’s physical safety. , 955 F.3d at 862–63; , 562 U.S. at 174.
- Lare v. Supreme Maint. Inc., No. 1:22-cv-00007 (D.N.M. Oct. 21, 2022). Id. at 172.
- Savignac v. Jones Day, 486 F. Supp. 3d 14 (D.D.C. 2020).published
- Greg Tolar v. Marion Bank & Trust, No. 19-11546 (11th Cir. May 17, 2021).published
- Greg Tolar v. Bradley Arant Boult Commings, LLC, 997 F.3d 1280 (11th Cir. 2021).published
- George v. Repub. Airways Inc., No. 1:20-cv-01702 (S.D. Ind. Mar. 17, 2021).
- Coomes v. Repub. Airline Inc., No. 1:19-cv-00034 (S.D. Ind. Mar. 26, 2021).
- Manuel Zamora v. City of Houston, 425 F. App'x 314 (5th Cir. 2011).unpublished
- Jeanetta Nailon v. Univ. of Cincinnati, No. 16-4691 (6th Cir. Nov. 9, 2017).unpublished
- Brown Vs. Eddie World, 348 P.3d 1002 (Nev. 2015).published
- Coleman v. Home Health Resources Inc., 269 F. Supp. 3d 935 (D. Ariz. 2017).published
- Equal Emp. Opportunity Comm'n v. NDI Off. Furniture, LLC, No. 2:18-cv-01592 (N.D. Ala. June 25, 2021).
- Hamilton v. Oswego Cmty. Unit Sch. Dist. 308, No. 1:20-cv-00292, 2021 WL 767619 (N.D. Ill. Feb. 26, 2021).
- Threat v. City of Cleveland, No. 1:19-cv-02105 (N.D. Ohio July 31, 2020).
- Norfolk v. Geo Grp., Inc., No. 3:17-cv-00204, 2020 WL 1873991 (W.D. Pa. Apr. 15, 2020).
- Jones v. Vilsack, 861 F. App'x 58 (M.D. Tenn. 2020).unpublished
- Tracy Ehmann v. Oshkosh Corp., No. 1:19-cv-01128 (E.D. Wis. Nov. 20, 2019).
- Strzykalski v. Bd. of Educ. of Summit Hill Sch. Dist. 161, No. 1:23-cv-01284 (N.D. Ill. June 25, 2025).
- Patton v. Forest River Inc, No. 3:18-cv-00419 (N.D. Ind. Feb. 18, 2020).
- Gueber v. Cmty. Health Sys., No. 1:17-cv-00439 (N.D. Ind. Mar. 5, 2021).
- Graham v. Coca-Cola Consol., No. 3:19-cv-00386 (N.D. Ind. Oct. 27, 2021).
- Robinson v. Wawasee Cmty. Sch. Corp., No. 3:19-cv-00041 (N.D. Ind. Jan. 24, 2022).
- Szeinbach v. Ohio State Univ., 493 F. App'x 690 (6th Cir. 2012).unpublished
- Harrigan v. Carson, No. 2017-0930 (D.D.C. Sept. 28, 2019).published
At page 173 Interpreting title vii's antiretaliation provision scope30 citing cases“must be construed to cover a broad range of employer conduct.”
- Richardson v. Tri-State Iron & Metal Co., No. 4:19-cv-04095 (W.D. Ark. May 6, 2021). See Thompson v. North American Stainless, LP, 562 U.S. at 175 (“We must also decline to identify a fixed class of relationships for which third-party reprisals are unlawful.
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published “Shareholders are not within Title VII’s zone of 10 See Thompson, 562 U.S. at 178 (“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.”). 11 Sec.
- Brittany Tovar v. Essentia Health, 857 F.3d 771 (8th Cir. 2017).published See id. at 178 ("Thompson was an employee of NAS, and the purpose of Title VII is to protect employees from their employers' unlawful actions."). -8- For the foregoing reasons we agree with the district court that Title VII and the MHRA do…
- Brisbois v. Soo Line R.R., 124 F. Supp. 3d 891 (D. Minn. 2015).published (... Title VII’s antiretaliation provision must be construed to cover a broad range of employer conduct)
- Portland State Univ. Chapter of the Am. Ass'n of Univ. Professors v. Portland State Univ., 291 P.3d 658 (Or. 2012).published (Title VII’s antiretaliation provision must be construed to cover a broad range of employer conduct.)
- Townsend v. Benjamin Enter., Inc., 679 F.3d 41 (2d Cir. 2012).published (Title VII’s anti-retaliation provision must be construed to cover a broad range of employer conduct.)
- Tepperwien v. Entergy Nuclear Operations, Inc., 663 F.3d 556 (2d Cir. 2011).published (Title VII's antiretaliation provision must *568 be construed to cover a broad range of employer conduct.)
- Hakeem Abayomi v. Douglas A. Collins, 182 F.4th 587 (7th Cir. 2026).publishedThompson v. N. Am. Stainless, LP, 562 U.S. 170, 173 (2011).
- Heagney v. Garland, No. 2024-2592 (D.D.C. May 22, 2025).published To the contrary, Title VII’s antiretaliation provision “must be construed to cover a broad range of employer conduct.” Id. at 173.
- Richard Miller v. Michigan Dep't of Corr., 15 N.W.3d 129 (Mich. 2024).published The Court noted that the antidiscrimination prohibitions of Title VII were limited to actions “with respect to . . . compensation, terms, conditions, or privileges of employment,” while the antiretaliation prohibitions of Title VII covered…
Show 19 more citing cases
- Jenai Hayes v. Metro. Gov't of Nashville, No. 23-5075 (6th Cir. Dec. 13, 2023).unpublished Thompson, 562 U.S. at 174. - 12 - Nos. 23-5027/5075, Hayes v. Metro.
- Greg Tolar v. Marion Bank & Trust, No. 19-11546 (11th Cir. May 17, 2021).published
- Greg Tolar v. Bradley Arant Boult Commings, LLC, 997 F.3d 1280 (11th Cir. 2021).published
- Adams v. Anne Arundel Cnty. Pub. Schs., 789 F.3d 422 (4th Cir. 2015).published
- Corey v. Prof'l Rodeo Cowboys Ass'n, No. 1:18-cv-01682 (D. Colo. Feb. 7, 2020).
- George v. Repub. Airways Inc., No. 1:20-cv-01702 (S.D. Ind. Mar. 17, 2021).
- Coomes v. Repub. Airline Inc., No. 1:19-cv-00034 (S.D. Ind. Mar. 26, 2021).
- Vigil v. STS Sys. Integration, LLC, No. 3:18-cv-00324 (S.D. Ohio Sept. 25, 2019).
- Grp. Home on Gibson Island, LLC v. Gibson Island Corp., 144 F.4th 522 (4th Cir. 2025).published
- Hovsepyan v. Blaya, 770 F. Supp. 2d 259 (D.D.C. 2011).published
- Saji v. Nassau Univ. Med. Ctr., No. 17-878 (2d Cir. Jan. 30, 2018).unpublished
- St. Juste v. Metro Plus Health Plan, 8 F. Supp. 3d 287 (E.D.N.Y. 2014).published
- Batchelor v. City of New York, 12 F. Supp. 3d 458 (E.D.N.Y. 2014).published
- Bowen-Hooks v. City of New York, 13 F. Supp. 3d 179 (E.D.N.Y. 2014).published
- Dall v. St. Catherine of Siena Med. Ctr., 966 F. Supp. 2d 167 (E.D.N.Y. 2013).published
- Patton v. Forest River Inc, No. 3:18-cv-00419 (N.D. Ind. Feb. 18, 2020).
- Gueber v. Cmty. Health Sys., No. 1:17-cv-00439 (N.D. Ind. Mar. 5, 2021).
- Graham v. Coca-Cola Consol., No. 3:19-cv-00386 (N.D. Ind. Oct. 27, 2021).
- Robinson v. Wawasee Cmty. Sch. Corp., No. 3:19-cv-00041 (N.D. Ind. Jan. 24, 2022).
At page 175 Defining the scope of title vii retaliation standards23 citing casesWe must also decline to identify a fixed class of relationships for which third-party reprisals are unlawful. We expect that firing a close family member will almost always meet the Burlington standard, and inflicting a milder reprisal on a mere acquaintance will almost never do so, but beyond tha…
- Davis v. Vt State Colleges, No. 25-cv-2503 (Vt. Super. Ct. Jan. 22, 2026). (We expect that firing a close family member will almost always meet the Burlington standard, and inflicting a milder reprisal on a mere acquaintance will almost never do so, but beyond that we are reluctant to generali…)
- Nazariy Lesiv v. Illinois Cent. R.R. Com, 39 F.4th 903 (7th Cir. 2022).published (Given the broad statutory text and the variety of workplace contexts in which retaliation may oc- cur, Title VII’s antiretaliation provision is simply not reduci- ble to a comprehensive set of clear rules.)
- Simmons v. Alabama State Univ., No. 2:18-cv-00640 (M.D. Ala. Aug. 3, 2021). See Thompson, 562 U.S. at 178 (“[I]njuring him was the employer’s intended means of harming [her, the complaining employee].
- Richardson v. Tri-State Iron & Metal Co., No. 4:19-cv-04095 (W.D. Ark. May 6, 2021). (We must also decline to identify a fixed class of relationships for which third-party reprisals are unlawful. We expect that firing a close family member will almost always meet the Burlington standard, and inflicting…)
- Tromblee v. State of New York, No. 1:19-cv-00638 (N.D.N.Y. Mar. 16, 2021). See Thompson, 562 U.S. at 174 (“We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her [fiancée] would be fired.”).11 The Supreme Court regarded the issue of that family mem…
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published “Shareholders are not within Title VII’s zone of 10 See Thompson, 562 U.S. at 178 (“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.”). 11 Sec.
- Morgan v. Napolitano, 988 F. Supp. 2d 1162 (E.D. Cal. 2013).published “title vii's antiretaliation provision is worded broadly. we think there is no textual basis for making an exception to it for third-party reprisals, and a preference for clear rules cannot justify departing from statuto…”
- Rubicon Real Est. Holdings, LLC v. Pontiac, City of, 791 F. Supp. 3d 761 (E.D. Mich. 2025).published Thompson, 562 U.S. at 174, 178.
- Heagney v. Garland, No. 2024-2592 (D.D.C. May 22, 2025).published To the contrary, Title VII’s antiretaliation provision “must be construed to cover a broad range of employer conduct.” Id. at 173.
- Anthony Defrancesco v. Robert C. Robbins, 136 F.4th 933 (9th Cir. 2025).publishedThompson, however, concerned a distinct statutory right, based on an antiretaliation provision that was “worded broadly.” Id. at 175.
Show 13 more citing cases
- Conviser v. DePaul Univ., 649 F. Supp. 3d 686 (N.D. Ill. 2023).published In Thompson, the Supreme Court read Title VII’s antiretaliation provision as broad enough to encompass an employee who was fired in retaliation for a discrimination charge filed by a fiancé, declining to impose a “categorical rule that thi…
- Lare v. Supreme Maint. Inc., No. 1:22-cv-00007 (D.N.M. Oct. 21, 2022). Id. at 172.
- Greg Tolar v. Marion Bank & Trust, No. 19-11546 (11th Cir. May 17, 2021).published
- Greg Tolar v. Bradley Arant Boult Commings, LLC, 997 F.3d 1280 (11th Cir. 2021).published
- Gipson v. Hyundai Power Transformers, USA, Inc. (LEAD), No. 2:19-cv-00224 (M.D. Ala. Mar. 17, 2020).
- George v. Repub. Airways Inc., No. 1:20-cv-01702 (S.D. Ind. Mar. 17, 2021).
- Jeanetta Nailon v. Univ. of Cincinnati, No. 16-4691 (6th Cir. Nov. 9, 2017).unpublished
- Michael Threat v. City of Cleveland, 6 F.4th 672 (6th Cir. 2021).published
- P.P. v. Compton Unified Sch. Dist., 135 F. Supp. 3d 1098 (C.D. Cal. 2015).published
- Schroeder v. DeJoy, No. 2:17-cv-01301 (D. Ariz. Sept. 10, 2019).
- Lee v. Denver Pub. Schs., No. 1:20-cv-01989 (D. Colo. Mar. 29, 2021).
- Bogden-Cozmuta v. Granby Urgent Care, LLC, No. 3:20-cv-00879, 2022 WL 4585442 (D. Conn. Sept. 29, 2022).
- Aslin v. Univ. of Rochester, No. 6:17-cv-06847, 2019 WL 4112130 (W.D.N.Y. Aug. 28, 2019).
At page 178 Defining the zone of interests under title vii22 citing cases“the purpose of title vii is to protect employees from their employers' unlawful actions.”
- Nazariy Lesiv v. Illinois Cent. R.R. Com, 39 F.4th 903 (7th Cir. 2022).published See Thompson, 562 U.S. at 175 (“Given the broad statutory text and the variety of workplace contexts in which retaliation may oc- cur, Title VII’s antiretaliation provision is simply not reduci- ble to a comprehensive set of clear rules.”)…
- Simmons v. Alabama State Univ., No. 2:18-cv-00640 (M.D. Ala. Aug. 3, 2021). ([I]njuring him was the employer’s intended means of harming [her, the complaining employee]. Hurting him was the unlawful 10 act by which the employer punished her.)
- Tromblee v. State of New York, No. 1:19-cv-00638 (N.D.N.Y. Mar. 16, 2021). See Thompson, 562 U.S. at 174 (“We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her [fiancée] would be fired.”).11 The Supreme Court regarded the issue of that family mem…
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published ([T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.)
- Brittany Tovar v. Essentia Health, 857 F.3d 771 (8th Cir. 2017).published (Thompson was an employee of NAS, and the purpose of Title VII is to protect employees from their employers' unlawful actions.)
- Abbananto v. Cnty. of Nassau, No. 2:19-cv-01102 (E.D.N.Y. Feb. 3, 2022).“we hold that the term 'aggrieved' in title vii . . . enables suit by any plaintiff with an interest 'arguably sought to be protected by the statute' while excluding plaintiffs who might technically be injured in an arti…”
- Nchotebah v. UTMB Corr. Managed Care, No. 9:20-cv-00004 (E.D. Tex. Oct. 14, 2020).([T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.)
- DOE v. Twp. High Sch. Dist. No. 214, No. 1:19-cv-03052, 2020 WL 1081726 (N.D. Ill. Mar. 6, 2020). Thompson v. N. Am. Stainless, LP, 562 U.S. 170 , 176-77 (2011); Richards v. N.L.R.B., 702 F.3d 1010, 1014 (7th Cir. 2012) (“However, the Supreme Court recently held that a similar ‘aggrieved’ requirement in Title VII did not refer to ‘anyo…
- FDA v. R. J. Reynolds Vapor Co., 606 U.S. 226 (2025).published See, e.g., Bank of America Corp. v. Miami, 581 U. S. 189, 193 (interpreting “aggrieved person” in the Fair Housing Act); Thompson v. North American Stainless, LP, 562 U. S. 170, 177 (interpreting “person claiming to be aggrieved” in Title…
- Hunter v. Dove, 711 F. Supp. 3d 862 (S.D. Ohio 2024).published“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions”
Show 12 more citing cases
- Lare v. Supreme Maint. Inc., No. 1:22-cv-00007 (D.N.M. Oct. 21, 2022). Id. at 172.
- Greg Tolar v. Marion Bank & Trust, No. 19-11546 (11th Cir. May 17, 2021).published
- Greg Tolar v. Bradley Arant Boult Commings, LLC, 997 F.3d 1280 (11th Cir. 2021).published
- Simmons v. UBS Fin. Servs., Inc., No. 4:19-cv-03301 (S.D. Tex. Jan. 6, 2020).
- George v. Repub. Airways Inc., No. 1:20-cv-01702 (S.D. Ind. Mar. 17, 2021).
- P.P. v. Compton Unified Sch. Dist., 135 F. Supp. 3d 1098 (C.D. Cal. 2015).published
- Riggs v. Bennett Cnty. Hosp. & Nursing Home, No. 5:16-cv-05077, 2019 WL 1441205 (D.S.D. Mar. 31, 2019).
- Santiago Pineda v. JTCH Apts., L.L.C., 843 F.3d 1062 (5th Cir. 2016).published
- Patrick Collins v. Steven Mnuchin, Secretar, 938 F.3d 553 (5th Cir. 2019).published
- Tovar v. Essentia Health, 187 F. Supp. 3d 1055 (D. Minn. 2016).published
- Kastor v. Cash Express of Tennessee, LLC, 77 F. Supp. 3d 605 (W.D. Ky. 2015).published
- Jesus v. Lamar Advertisement, LLC, No. 1:21-cv-00230 (S.D. Miss. Sept. 23, 2021).
131 S. Ct. at 868 Analyzing scope of third-party retaliation under Title VII17 citing casesaddressing the unlawfulness of an employer’s third-party reprisal
- Ali v. Dist. of Columbia Gov't, 810 F. Supp. 2d 78 (D.D.C. 2011).published Stainless, LB, — U.S.-, 131 S.Ct. 863 , 868, 178 L.Ed.2d 694 (2011) (“We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired.”); see also DeMedina v. R…
- Manuel Zamora v. City of Houston, 425 F. App'x 314 (5th Cir. 2011).unpublished
- Byron Underwood v. Dep't of Fin. Servs. State of Florida, 518 F. App'x 637 (11th Cir. 2013).unpublished
- Blount v. Morgan Stanley Smith Barney LLC, 982 F. Supp. 2d 1077 (N.D. Cal. 2013).published
- Trimble v. All.-DeKalb/Rock-Tenn Co., 801 F. Supp. 2d 764 (N.D. Ill. 2011).published
- Dembin v. Lvi Servs., Inc., 822 F. Supp. 2d 436 (S.D.N.Y. 2011).published
- Herbert v. Architect of the Capitol, 766 F. Supp. 2d 59 (D.D.C. 2011).published
- Perry v. Kappos, 776 F. Supp. 2d 182 (E.D. Va. 2011).published
- Taylor v. Mills, 892 F. Supp. 2d 124 (D.D.C. 2012).published
- Herbert v. Architect of the Capitol, 839 F. Supp. 2d 284 (D.D.C. 2012).published
Show 7 more citing cases
- Ramsey v. Moniz, 75 F. Supp. 3d 29 (D.D.C. 2014).published
- Wigent v. Sci. Applications Int'l Corp., 19 F. Supp. 3d 1012 (D. Haw. 2014).published
- Lorenzo v. St. Luke's-Roosevelt Hosp. Ctr., 837 F. Supp. 2d 53 (E.D.N.Y. 2011).published
- Rodriguez-Vega v. Policlinica La Familia De Toa Alta, Inc., 942 F. Supp. 2d 210 (D.P.R. 2013).published
- Finn v. Kent Sec. Servs., Inc., 981 F. Supp. 2d 1293 (S.D. Fla. 2013).published
- One Fair Wage, Inc. v. Darden Restaurants Inc., No. 3:21-cv-02695 (N.D. Cal. Sept. 14, 2021).
- Kelly v. First Data Corp., No. 1:19-cv-00372, 2020 WL 419440 (S.D. Ohio Jan. 27, 2020).
At page 177 Interpreting "aggrieved person" under statutory zone of interests16 citing casesrejecting the argument that only “the person who was the subject of unlawful retaliation” could bring suit, characterizing that position as “artificially narrow
- Tromblee v. State of New York, No. 1:19-cv-00638 (N.D.N.Y. Mar. 16, 2021). See Thompson, 562 U.S. at 174 (“We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her [fiancée] would be fired.”).11 The Supreme Court regarded the issue of that family mem…
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published “Shareholders are not within Title VII’s zone of 10 See Thompson, 562 U.S. at 178 (“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.”). 11 Sec.
- Rynkiewicz, No. 2:26-cv-00525 (E.D. Pa. June 16, 2026). (rejecting the argument that only “the person who was the subject of unlawful retaliation” could bring suit, characterizing that position as “artificially narrow)
- Nance, No. 9:25-cv-00004 (D. Mont. Apr. 28, 2026).(Doc. 41 at 25.) Plaintiffs contend that even if Clifford cannot show he personally engaged in a protected activity that the Ninth Circuit allows Clifford to sue based on falling within the “zone of interests.” (Id. (citing Thompson v. Nor…
- FDA v. R. J. Reynolds Vapor Co., 606 U.S. 226 (2025).published (interpreting “person claiming to be aggrieved” in Title VII)
- Connectors Realty Grp. Corp., The v. State Farm Fire & Cas. Co., No. 1:19-cv-00743 (N.D. Ill. Aug. 21, 2024). Id. at 176.
- Lare v. Supreme Maint. Inc., No. 1:22-cv-00007 (D.N.M. Oct. 21, 2022). Id. at 172.
- Greg Tolar v. Marion Bank & Trust, No. 19-11546 (11th Cir. May 17, 2021).published
- Greg Tolar v. Bradley Arant Boult Commings, LLC, 997 F.3d 1280 (11th Cir. 2021).published
- Simmons v. UBS Fin. Servs., Inc., No. 4:19-cv-03301 (S.D. Tex. Jan. 6, 2020).
Show 6 more citing cases
- George v. Repub. Airways Inc., No. 1:20-cv-01702 (S.D. Ind. Mar. 17, 2021).
- P.P. v. Compton Unified Sch. Dist., 135 F. Supp. 3d 1098 (C.D. Cal. 2015).published
- A. B. v. Hawaii State Dept of Educ., 30 F.4th 828 (9th Cir. 2022).published
- Friends of Trumbull v. Chicago Bd. of Educ., 123 F. Supp. 3d 990 (N.D. Ill. 2015).published
- Riggs v. Bennett Cnty. Hosp. & Nursing Home, No. 5:16-cv-05077, 2019 WL 1441205 (D.S.D. Mar. 31, 2019).
- Neshaminy S.D. v. P.H.R.C., No. 1765 C.D. 2019 (Pa. Commw. Ct. June 7, 2021).published
At page 172 Defining the scope of employment relationship11 citing cases
- Tromblee v. State of New York, No. 1:19-cv-00638 (N.D.N.Y. Mar. 16, 2021). See Thompson, 562 U.S. at 174 (“We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her [fiancée] would be fired.”).11 The Supreme Court regarded the issue of that family mem…
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published “Shareholders are not within Title VII’s zone of 10 See Thompson, 562 U.S. at 178 (“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.”). 11 Sec.
- Brittany Tovar v. Essentia Health, 857 F.3d 771 (8th Cir. 2017).published See id. at 178 ("Thompson was an employee of NAS, and the purpose of Title VII is to protect employees from their employers' unlawful actions."). -8- For the foregoing reasons we agree with the district court that Title VII and the MHRA do…
- McGinnis, No. 1:25-cv-02138 (D. Md. Jan. 28, 2026). In Thompson, an engaged couple, Thompson and Regalado, were employed by the same company. 562 U.S. at 172.
- Conviser v. DePaul Univ., 649 F. Supp. 3d 686 (N.D. Ill. 2023).published In Thompson, the Supreme Court read Title VII’s antiretaliation provision as broad enough to encompass an employee who was fired in retaliation for a discrimination charge filed by a fiancé, declining to impose a “categorical rule that thi…
- Lare v. Supreme Maint. Inc., No. 1:22-cv-00007 (D.N.M. Oct. 21, 2022). Id. at 172.
- Savignac v. Jones Day, 486 F. Supp. 3d 14 (D.D.C. 2020).published
- Greg Tolar v. Marion Bank & Trust, No. 19-11546 (11th Cir. May 17, 2021).published
- Greg Tolar v. Bradley Arant Boult Commings, LLC, 997 F.3d 1280 (11th Cir. 2021).published
- Gipson v. Hyundai Power Transformers, USA, Inc. (LEAD), No. 2:19-cv-00224 (M.D. Ala. Mar. 17, 2020).
Show 1 more citing case
- Simmons v. UBS Fin. Servs., Inc., No. 4:19-cv-03301 (S.D. Tex. Jan. 6, 2020).
131 S. Ct. at 870 Defining the zone of interests for title vii standing10 citing casesconcluding that Thompson falls within the zone of interests protected by Title VII because he is a person aggrieved with standing to sue
- Byron Underwood v. Dep't of Fin. Servs. State of Florida, 518 F. App'x 637 (11th Cir. 2013).unpublished
- Jackson v. Deen, 959 F. Supp. 2d 1346 (S.D. Ga. 2013).published
- Perry v. Kappos, 776 F. Supp. 2d 182 (E.D. Va. 2011).published
- One Fair Wage, Inc. v. Darden Restaurants Inc., No. 3:21-cv-02695 (N.D. Cal. Sept. 14, 2021).
- City of Los Angeles v. Wells Fargo & Co., 22 F. Supp. 3d 1047 (C.D. Cal. 2014).published
- Cochran v. Five Points Temporaries, LLC, 907 F. Supp. 2d 1260 (N.D. Ala. 2012).published
- Valerie Montone v. City of Jersey City, 709 F.3d 181 (3d Cir. 2013).published
- Equal Rights Ctr. v. Equity Residential, 798 F. Supp. 2d 707 (D. Md. 2011).published
- Todd v. Collecto, Inc., 731 F.3d 734 (7th Cir. 2013).published
- Veronica Ollier v. Sweetwater Union High Sch., 768 F.3d 843 (9th Cir. 2014).published
At page 176 Analyzing standing requirements under title vii and title viii7 citing cases“later opinions, we must acknowledge, reiterate that the term 'aggrieved' in the fha reaches as far as article iii permits”
- James Simmons v. UBS Fin. Servs., Inc., 972 F.3d 664 (5th Cir. 2020).published “Shareholders are not within Title VII’s zone of 10 See Thompson, 562 U.S. at 178 (“[T]he purpose of Title VII is to protect employees from their employers’ unlawful actions.”). 11 Sec.
- Third Space Partners, LLC v. 668 Atrium, LLC, No. 1:26-cv-00568 (N.D. Ohio July 10, 2026).“later opinions, we must acknowledge, reiterate that the term 'aggrieved' ... reaches as far as article iii permits.”
- Bank of Am. Corp. v. City of Miami, 581 U.S. 189 (2017).published “later opinions, we must acknowledge, reiterate that the term 'aggrieved' in the fha reaches as far as article iii permits”
- Jones, No. 1:24-cv-01085 (S.D. Ind. Jan. 29, 2026).Id. at 176-78.
- FDA v. R. J. Reynolds Vapor Co., 606 U.S. 226 (2025).published See, e.g., Bank of America Corp. v. Miami, 581 U. S. 189, 193 (interpreting “aggrieved person” in the Fair Housing Act); Thompson v. North American Stainless, LP, 562 U. S. 170, 177 (interpreting “person claiming to be aggrieved” in Title…
- Connectors Realty Grp. Corp., The v. State Farm Fire & Cas. Co., No. 1:19-cv-00743 (N.D. Ill. Aug. 21, 2024). Id. at 176.
- FCS Advisors, LLC v. State of Missouri, No. 2:17-cv-04089 (W.D. Mo. Oct. 16, 2017).
131 S. Ct. at 867 Analyzing the scope of employment liability for employer actions5 citing cases
- Byron Underwood v. Dep't of Fin. Servs. State of Florida, 518 F. App'x 637 (11th Cir. 2013).unpublished
- Seale v. Madison Cnty, 929 F. Supp. 2d 51 (N.D.N.Y. 2013).published
- Jackson v. Deen, 959 F. Supp. 2d 1346 (S.D. Ga. 2013).published
- Blount v. Morgan Stanley Smith Barney LLC, 982 F. Supp. 2d 1077 (N.D. Cal. 2013).published
- EEOC v. Fred Fuller Oil Co., 2014 DNH 020 (D.N.H. 2014).published
131 S. Ct. at 869 Distinguishing between title vii and title viii claims5 citing cases
- Byron Underwood v. Dep't of Fin. Servs. State of Florida, 518 F. App'x 637 (11th Cir. 2013).unpublished
- Jackson v. Deen, 959 F. Supp. 2d 1346 (S.D. Ga. 2013).published
- State of New Hampshire v. Holder, 293 F.R.D. 1 (D.D.C. 2013).published
- City of Los Angeles v. Wells Fargo & Co., 22 F. Supp. 3d 1047 (C.D. Cal. 2014).published
- Cochran v. Five Points Temporaries, LLC, 907 F. Supp. 2d 1260 (N.D. Ala. 2012).published
At page 179 EEOC counsel on title vii retaliation against relatives4 citing casesJ. Ginsberg, concurring
- Tromblee v. State of New York, No. 1:19-cv-00638 (N.D.N.Y. Mar. 16, 2021). See Thompson, 562 U.S. at 174 (“We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her [fiancée] would be fired.”).11 The Supreme Court regarded the issue of that family mem…
- Simmons v. UBS Fin. Servs., Inc., No. 4:19-cv-03301 (S.D. Tex. Jan. 6, 2020).
- Equal Emp. Opportunity Comm'n v. NDI Off. Furniture, LLC, No. 2:18-cv-01592 (N.D. Ala. June 25, 2021).
- Riggs v. Bennett Cnty. Hosp. & Nursing Home, No. 5:16-cv-05077, 2019 WL 1441205 (D.S.D. Mar. 31, 2019).
Later opinions, we must acknowledge, reiterate that the term ‘aggrieved’ … reaches as far as Article III permits[.]
- Third Space Partners, LLC v. 668 Atrium, LLC, No. 1:26-cv-00568 (N.D. Ohio July 10, 2026).(Later opinions, we must acknowledge, reiterate that the term ‘aggrieved’ … reaches as far as Article III permits[.])
- Bank of Am. Corp. v. City of Miami, 581 U.S. 189 (2017).published (Later opinions, we must acknowledge, reiterate that the term 'aggrieved' [in the FHA] reaches as far as Article III permits)
Claims under the PHRA are interpreted coextensively with Title VII claims.
- Preston v. Bain, No. 2:20-cv-04194 (E.D. Pa. Sept. 22, 2021). (Claims under the PHRA are interpreted coextensively with Title VII claims.)
- Bates v. Montgomery Cnty., No. 2:20-cv-02956 (E.D. Pa. Sept. 17, 2021).(Claims under the PHRA are interpreted coextensively with Title VII claims.)
“claims under the phra are interpreted coextensively with title vii claims.”
- Preston v. Bain, No. 2:20-cv-04194 (E.D. Pa. Sept. 22, 2021). “claims under the phra are interpreted coextensively with title vii claims.”
- Bates v. Montgomery Cnty., No. 2:20-cv-02956 (E.D. Pa. Sept. 17, 2021).“claims under the phra are interpreted coextensively with title vii claims.”
Other citing cases
- James, No. 3:25-cv-00773 (W.D. La. June 3, 2026).
- Brower v. Roose, No. 2:24-cv-10702, 2024 WL 1694860 (E.D. Mich. Apr. 19, 2024).
- Oldridge v. Wichita, No. 6:21-cv-01284 (D. Kan. Nov. 30, 2022).
- Eaton v. Montana Silversmiths, No. 1:18-cv-00065 (D. Mont. Sept. 28, 2021).
- Veljkovic v. Bd. of Educ. of the City of Chicago, No. 1:20-cv-01551, 2020 WL 7626735 (N.D. Ill. Dec. 22, 2020).
- Lewis v. Eufaula City Bd. of Educ., 922 F. Supp. 2d 1291 (M.D. Ala. 2012).published
v.
North American Stainless, Lp
Lead Opinion
delivered the opinion of the Court.
Until 2003, both petitioner Eric Thompson and his fiance, Miriam Regalado, were employees of respondent North American Stainless (NAS). In February 2003, the Equal Employment Opportunity Commission (EEOC) notified NAS that Regalado had filed a charge alleging sex discrimination. Three weeks later, NAS fired Thompson.
Thompson then filed a charge with the EEOC. After conciliation efforts proved unsuccessful, he sued NAS in the United States District Court for the Eastern District of Kentucky under Title VII of the Civil Rights Act of 1964, 78 Stat. 253, 42 U. S. C. § 2000e et seq., claiming that NAS had fired him in order to retaliate against Regalado for filing her charge with the EEOC. The District Court granted summary judgment to NAS, concluding that Title VII “does not permit third party retaliation claims.” 435 F. Supp. 2d 633, 639 (ED Ky. 2006). After a panel of the Sixth Circuit reversed the District Court, the Sixth Circuit granted rehearing en banc and affirmed by a 10-to-6 vote. 567 F. 3d 804 (2009). The court reasoned that because Thompson did not “engag[e] in any statutorily protected activity, either on his own behalf or on behalf of Miriam Regalado,” he “is not in-[*173]eluded in the class of persons for whom Congress created a retaliation cause of action.” Id., at 807-808.
We granted certiorari. 561 U. S. 1041 (2010).
I
Title VII provides that “[i]t shall be an unlawful employment practice for an employer to discriminate against any of his employees ... because he has made a charge” under Title VII. 42 U. S. C. § 2000e-3(a). The statute permits “a person claiming to be aggrieved” to file a charge with the EEOC alleging that the employer committed an unlawful employment practice, and, if the EEOC declines to sue the employer, it permits a civil action to “be brought ... by the person claiming to be aggrieved ... by the alleged unlawful employment practice.” §2000e-5(b), (f)(1).
It is undisputed that Regalado’s filing of a charge with the EEOC was protected conduct under Title VII. In the procedural posture of this case, we are also required to assume that NAS fired Thompson in order to retaliate against Regalado for filing a charge of discrimination. This case therefore presents two questions: First, did NAS’s firing of Thompson constitute unlawful retaliation? And second, if it did, does Title VII grant Thompson a cause of action?
II
With regard to the first question, we have little difficulty concluding that if the facts alleged by Thompson are true, then NAS’s firing of Thompson violated Title VII. In Burlington N. & S. F. R. Co. v. White, 548 U. S. 53 (2006), we held that Title VII’s antiretaliation provision must be construed to cover a broad range of employer conduct. We reached that conclusion by contrasting the text of Title VII’s antiretaliation provision with its substantive antidiscrimination provision. Title VII prohibits discrimination on the basis of race, color, religion, sex, and national origin “ ‘with respect to ... compensation, terms, conditions, or privileges[*174] of employment/” and discriminatory practices that would “ 'deprive any individual of employment opportunities or otherwise adversely affect his status as an employee.’” Id., at 62 (quoting 42 U. S. C. § 2000e-2(a); emphasis deleted). In contrast, Title VII’s antiretaliation provision prohibits an employer from " 'discriminating] against any of his employees’ ” for engaging in protected conduct, without specifying the employer acts that are prohibited. 548 U. S., at 62 (quoting §2000e-3(a); emphasis deleted). Based on this textual distinction and our understanding of the antiretaliation provision’s purpose, we held that ''the antiretaliation provision, unlike the substantive provision, is not limited to discriminatory actions that affect the terms and conditions of employment.” Id., at 64. Rather, Title YII’s antiretaliation provision prohibits any employer action that “well might have dissuaded a reasonable worker from making or supporting a charge of discrimination.” Id., at 68 (internal quotation marks omitted).
We think it obvious that a reasonable worker might be dissuaded from engaging in protected activity if she knew that her fiance would be fired. Indeed, NAS does not dispute that Thompson’s firing meets the standard set forth in Burlington. Tr. of Oral Arg. 30. NAS raises the concern, however, that prohibiting reprisals against third parties will lead to difficult line-drawing problems concerning the types of relationships entitled to protection. Perhaps retaliating against an employee by firing his fiance would dissuade the employee from engaging in protected activity, but what about firing an employee’s girlfriend, close friend, or trusted co-worker? Applying the Burlington standard to third-party reprisals, NAS argues, will place the employer at risk any time it fires any employee who happens to have a connection to a different employee who filed a charge with the EEOC.
Although we acknowledge the force of this point, we do not think it justifies a categorical rule that third-party repri[*175]sals do not violate Title VIL As explained above, we adopted a broad standard in Burlington because Title VIPs antiretaliation provision is worded broadly. We think there is no textual basis for making an exception to it for third-party reprisals, and a preference for clear rules cannot justify departing from statutory text.
We must also decline to identify a fixed class of relationships for whieh third-party reprisals are unlawful. We expect that firing a close family member will almost always meet the Burlington standard, and inflicting a milder reprisal on a mere acquaintance will almost never do so, but beyond that we are reluctant to generalize. As we explained in Burlington, 548 U. S., at 69, "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. We emphasize, however, that "the provision’s standard for judging harm must be objective,” so as to “avoi[d] the uncertainties and unfair discrepancies that can plague a judicial effort to determine a plaintiff’s unusual subjective feelings.” Id., at 68-69.
Ill
The more difficult question in this case is whether Thompson may sue NAS for its alleged violation of Title VII. The statute provides that “a civil action may be brought ... by the person claiming to be aggrieved.” 42 U. S. C. §2000e-5(f)(1). The Sixth Circuit concluded that this provision was merely a reiteration of the requirement that the plaintiff have Article III standing. 567 F. 3d, at 808, n. 1. We do not understand how that can be. The provision unquestionably permits a person “claiming to be aggrieved” to bring “a civil action.” It is arguable that the aggrievement referred to is nothing more than the minimal Article III standing, which consists of injury in fact caused by the defendant[*176] and remediable by the court. See Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-561 (1992). But Thompson’s claim undoubtedly meets those requirements, so if that is indeed all that aggrievement consists of, he may sue.
We have suggested in dictum that the Title VII aggrievement requirement conferred a right to sue on all who satisfied Article III standing. Trafficante v. Metropolitan Life Ins. Co., 409 U. S. 205 (1972), involved the “person aggrieved” provision of Title VIII (the Fair Housing Act) rather than Title VII. In deciding the case, however, we relied upon, and cited with approval, a Third Circuit opinion involving Title VII, which, we said, “concluded that the words used showed ‘a congressional intention to define standing as broadly as is permitted by Article III of the Constitution.’ ” Id., at 209 (quoting Hackett v. McGuire Bros., Inc., 445 F. 2d 442, 446 (1971)). We think that dictum regarding Title VII was too expansive. Indeed, the Trafficante opinion did not adhere to it in expressing its Title VIII holding that residents of an apartment complex could sue the owner for his racial discrimination against prospective tenants. The opinion said that the “person aggrieved” of Title VIII was coextensive with Article III “insofar as tenants of the same housing unit that is charged with discrimination are concerned.” 409 U. S., at 209 (emphasis added). Later opinions, we must acknowledge, reiterate that the term “aggrieved” in Title VIII reaches as far as Article III permits, see Bennett v. Spear, 520 U. S. 154, 165-166 (1997); Gladstone, Realtors v. Village of Bellwood, 441 U. S. 91, 109 (1979), though the holdings of those cases are compatible with the “zone of interests” limitation that we discuss below. In any event, it is Title VII rather than Title VIII that is before us here, and as to that we are surely not bound by the Trafficante dictum.
We now find that this dictum was ill-considered, and we decline to follow it. If any person injured in the Article III sense by a Title VII violation could sue, absurd consequences[*177] would follow. For example, a shareholder would be able to sue a company for firing a valuable employee for racially discriminatory reasons, so long as he could show that the value of his stock decreased as a consequence. At oral argument Thompson acknowledged that such a suit would not lie, Tr. of Oral Arg. 5-6. We agree, and therefore conclude that the term “aggrieved” must be construed more narrowly than the outer boundaries of Article III.
At the other extreme from the position that “person aggrieved” means anyone with Article III standing, NAS argues that it is a term of art that refers only to the employee who engaged in the protected activity. We know of no other context in which the words carry this artificially narrow meaning, and if that is what Congress intended it would more naturally have said “person claiming to have been discriminated against” rather than “person claiming to be aggrieved.” We see no basis in text or prior practice for limiting the latter phrase to the person who was the subject of unlawful retaliation. Moreover, such a reading contradicts the very holding of Trafficante, which was that residents of an apartment complex were “person[s] aggrieved” by discrimination against prospective tenants. We see no reason why the same phrase in Title VII should be given a narrower meaning.
In our view there is a common usage of the term “person aggrieved” that avoids the extremity of equating it with Article III and yet is fully consistent with our application of the term in Trafficante. The Administrative Procedure Act, 5 U. S. C. § 551 et seq., authorizes suit to challenge a federal agency by any “person . . . adversely affected or aggrieved . . . within the meaning of a relevant statute.” §702. We have held that this language establishes a regime under which a plaintiff may not sue unless he “falls within the ‘zone of interests’ sought to be protected by the statutory provision whose violation forms the legal basis for his complaint.” Lujan v. National Wildlife Federation, 497 U. S. 871, 883[*178] (1990). We have described the “zone of interests” test as denying a right of review “if the plaintiff’s interests are so marginally related to or inconsistent with the purposes implicit in the statute that it cannot reasonably be assumed that Congress intended to permit the suit.” Clarke v. Securities Industry Assn., 479 U. S. 388, 399-400 (1987). We hold that the term “aggrieved” in Title VII incorporates this test, enabling suit by any plaintiff with an interest “arguably [sought] to be protected by the statute,” National Credit Union Admin. v. First Nat. Bank & Trust Co., 522 U. S. 479, 495 (1998) (internal quotation marks omitted), while excluding plaintiffs who might technically be injured in an Article III sense but whose interests are unrelated to the statutory prohibitions in Title VII.
Applying that test here, we conclude that Thompson falls within the zone of interests protected by Title VII. Thompson was an employee of NAS, and the purpose of Title VII is to protect employees from their employers’ unlawful actions. Moreover, accepting the facts as alleged, Thompson is not an accidental victim of the retaliation — collateral damage, so to speak, of the employer’s unlawful act. To the contrary, injuring him was the employer’s intended means of harming Regalado. Hurting him was the unlawful act by which the employer punished her. In those circumstances, we think Thompson well within the zone of interests sought to be protected by Title VII. He is a person aggrieved with standing to sue.
* * *
The judgment of the Sixth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
Justice Kagan took no part in the consideration or decision of this case.Concurrence
concurring.
I join the Court’s opinion, and add a fortifying observation: Today’s decision accords with the longstanding views of the Equal Employment Opportunity Commission (EEOC), the federal agency that administers Title VII. In its Compliance Manual, the EEOC counsels that Title VII “prohibit^] retaliation against someone so closely related to or associated with the person exercising his or her statutory rights that it would discourage or prevent the person from pursuing those rights.” Brief for United States as Amicus Curiae 12-13 (quoting EEOC Compliance Manual §8-II(C)(3) (1998)). Such retaliation “can be challenged,” the Manual affirms, “by both the individual who engaged in protected activity and the relative, where both are employees.” Id., at 25-26 (quoting Compliance Manual § 8-II(B)(3)(c)). The EEOC’s statements in the Manual merit deference under Skidmore v. Swift & Co., 323 U. S. 134 (1944). See Federal Express Corp. v. Holowecki, 552 U. S. 389, 399-400 (2008). The EEOC’s interpretation of Title VII, I farther note, is consistent with interpretations of analogous statutes by other federal agencies. See, e. g., NLRB v. Advertisers Mfg. Co., 823 F. 2d 1086, 1088-1089 (CA7 1987) (adopting NLRB’s position that retaliation against a relative violates the National Labor Relations Act); Tasty Baking Co. v. NLRB, 254 F. 3d 114, 127-128 (CADC 2001) (same), cited in Brief for United States as Amicus Curiae 11.