42 U.S.C. § 2000e

Section 2000e(b) permits entities that share control over employment terms to be treated as joint employers when applying Title VII’s employee threshold.

Virgo v. Riviera Beach Associates · filed 1994-09-01(b)

We find that actual control is a factor to be considered when deciding the "joint employer" issue, but the authority or power to control is also highly relevant. The district court found that Riviera Beach paid all costs and expenses related to all hotel employees and paid all expenses of operation. This actual exercise of authority and the retained authority described above, are a sufficient basis upon which to find Sterling Group and Riviera Beach to be joint employers.

Section 2000e(b)’s definition of employer can cover two entities as joint employers when their actual control and retained authority over employees support that finding.

Virgo v. Riviera Beach Associates, Ltd. · filed 1994-09-01(b)

We find that actual control is a factor to be considered when deciding the “joint employer” issue, but the authority or power to control is also highly relevant. ... This actual exercise of authority and the retained authority described above, are a sufficient basis upon which to find Sterling Group and Riviera Beach to be joint employers.

Section 2000e(b) permits employees of separate entities to be counted together toward Title VII’s fifteen-employee threshold when the entities are sufficiently related to form a single employer.

Fernot v. Crafts Inn, Inc. · filed 1995-08-02(b)

This court concludes that where, as in this case, some employees of one company simply manage another company as agents for and under the direction of a common owner and where the managing company does not have an interest or other interrelation with the managed company, the two companies are not sufficiently related for the number of their employees to be aggregated for purposes of Title VII jurisdiction.

Appointing a trustee who terminates a local union employee does not, by itself, make the international and local unions a single employer under Title VII.

Campbell v. International Brotherhood of Teamsters · filed 1999-07-08(b)

Accordingly, plaintiff cannot assert that IBT and Local 918 were single employers solely on the basis that IBT appointed a trustee who terminated plaintiffs employment.

Section 2000e(b) can treat a separate entity as an employer when it shares control over essential terms and conditions of employment.

Holmes v. FSR/TENNESSEE AFFORDABLE HOUSING FOUNDATION · filed 2000-05-30(b)

In order to hold FSR liable under Title VII, Holmes must show that FSR is an employer as defined by the statute. ... As such, a question of fact remains as to whether FSR is a joint employer of Holmes. Thus, summary judgment is not appropriate.

Section 2000e(b)'s definition of employer can encompass related corporations as a single or joint employer based on their operations, management, control of labor relations, and ownership.

Scheidecker v. Arvig Enterprises, Inc. · filed 2000-11-09(b)

These factors must be applied in the determination of “employer” under 42 U.S.C. § 2000e(b). ... Here, an analysis of the interrelation of operations, common management, centralized control of labor relations, and common ownership between Arvig Enterprises and RCSS reveals genuine issues of material fact over whether the two corporations operated as a single entity or joint employer for Title VII purposes.

Government entities with sufficiently interrelated control over an employee may be treated as a single employer under Title VII.

MacK v. Alabama Department of Human Resources · filed 2002-01-17(b)

The court is satisfied that there is a sufficient degree of interrelationship between the respective entities in these circumstances to conclude that there is at least a jury question as to the issue of whether or not they were all Mack’s employer for purposes of Title VII.

Section 2000e(b) can treat separate companies as a single employer when their operations, labor relations, management, and ownership or financial control are sufficiently integrated.

Smith v. K & F INDUSTRIES, INC. · filed 2002-03-20(b)

In light of the factual dispute under the “single employer” test, that Smith did not identify a particular Loral employee as having made discriminatory comments to her does not warrant Loral’s dismissal from the case.

Section 2000e(b)’s fifteen-employee threshold may be met by counting employees of two companies a jury could find to be a single employer.

Russo v. Lightning Fulfillment, Inc. · filed 2002-04-18(b)

Title VII defines “employer” as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” 42 U.S.C. § 2000e(b). ... Accordingly, as a jury could conclude that defendant and Tompac were a single employer from the facts alleged by plaintiff, defendant’s motion for summary judgment is denied on this ground.

A staffing agency and the company receiving its worker may both qualify as employers under Title VII.

Hurde v. Jobs Plus-Med · filed 2004-01-14(b)

Plaintiff has provided ample evidence for a reasonable jury to find that A-Plus and Jobs Plus were joint employers for purposes of Title VII.

An entity may be a joint employer under Title VII if it controls aspects of a worker’s employment, even if it did not directly hire her.

Krasner v. Episcopal Diocese of Long Island · filed 2006-05-13(b)

In this case, the Plaintiff argues that the Diocese may be liable to the Plaintiff even if it did not directly hire or employ her under the “joint employer” doctrine, if she can prove that the Diocese controlled certain aspects of her employment with the Church, including her compensation, privileges, terms, and conditions. The Court agrees. ... These contentions present genuine issues of material fact as to whether there was common ownership and control between the Diocese and the Church that preclude summary judgment.

Section 2000e permits an entity with sufficient control over another company’s employee to be treated as a joint employer under Title VII.

Ahanotu v. Massachusetts Turnpike Authority · filed 2006-12-08(b)

For purposes of Title VII liability, an entity may be considered a “joint employer” if it possesses sufficient control over the work of an employee of another company. ... While the plaintiff does not allege that he was on the B/PB payroll, he does allege facts sufficient to draw an inference that B/PB was a joint employer under the Orell test.

Related companies may qualify as joint employers when they share control over essential terms and conditions of employment; their combined employees may satisfy Title VII's 15-employee threshold.

White v. Golden · filed 2008-04-30(b)

An "employer" is a "person . . . who has fifteen or more employees for each working day in each of 20 or more calendar weeks in the current or preceding calendar year." 42 U.S.C. § 2000e(b). ... Our review of the record persuades us that plaintiff's statements contained in her affidavit created a genuine issue of material fact with regard to whether Infusion, AOSS Medical Supply, Inc. and AOSS Home Health Medical, Inc. were joint-employers for the purposes of Title VII.

Section 2000e(b) requires a staffing agency to exercise significant control over a worker’s employment to qualify as a joint employer.

Medina v. Adecco · filed 2008-06-12(b)

No fact finder considering these facts could reasonably infer that Adecco exercised the day-to-day control over Medina necessary to render Adecco jointly responsible for Medina’s termination.

Section 2000e(b) defines an employer; joint employer status depends on an entity’s control over the employee’s terms and conditions of employment.

Acosta v. Harbor Holdings & Operations, Inc. · filed 2009-12-21(b)

The “joint employer” doctrine seeks to hold an entity liable to an employee of another entity if the evidence shows that it sufficiently had power over the employee in question. ... However, inasmuch as the same individuals constituted the Board of Directors for both HH & O and SJBP the fact that these discussions were held during the SJBP meetings does not necessarily mean that it was SJBP who was making the decisions. This is particularly so when the corresponding letters—specifically those used by plaintiff as grounds for her discriminatory and retaliatory charges—were all issued by HH & O. Accordingly, the claims asserted against SJBP in these proceedings are DISMISSED.

Section 2000e(b) allows distinct entities to be liable as employers under Title VII when they jointly employ a worker or one acts as the other's agent.

Myers v. Garfield & Johnson Enterprises, Inc. · filed 2010-01-14(b)

I conclude that, in the Third Circuit, two distinct entities may be liable for the same Title VII violation not only when they constitute a “single employer” but also when they are joint employers of the plaintiff or when one entity acted as the agent of the other.

A staffing company’s control over essential employment terms can create a factual dispute about whether it is an employer under Title VII.

Fulton v. People Lease Corp. · filed 2010-03-05(b)

Based on the authorities discussed above and the evidentiary material submitted by the parties, we conclude a genuine issue of fact exists regarding PeopLease's status as Plaintiff's employer under Title VII.

Section 2000e’s definition of employer can include a company that shares control over a worker’s essential terms and conditions of employment with a contractor.

Boutin v. Exxon Mobil Corp. · filed 2010-07-30(b)

Applying the Second Circuit’s factors to the present record shows that as a matter of law, ExxonMobil was not Boutin’s joint employer.

Title VII permits joint employer status, but a plaintiff must allege facts supporting the defendant’s status as an employer.

Konah v. District of Columbia · filed 2011-09-14(b)

Nor does the Second Amended Complaint put forth any facts that might allow the court to conclude that the District was an employer under Spirides or Redd.

Section 2000e’s definition of employer can include entities that jointly control workers’ terms and conditions of employment; joint employer status alone does not establish liability for discrimination.

U.S. Equal Employment Opportunity Commission v. Global Horizons, Inc. · filed 2012-03-16(b)

Joint employer status merely establishes the employment relationship necessary for Title VII protections to apply to the Moving Defendants.

An entity may be a joint employer under Title VII when it shares control over another entity’s employees’ essential terms and conditions of employment.

Williams v. City of Columbus · filed 2012-09-12(b)

Because there is a genuine issue of material fact as to whether the City acted as Williams’s joint employer with the Municipal Court, the City’s Motion for Summary Judgment is DENIED.

A plaintiff may plausibly allege that related corporations are joint or single employers under Title VII by pleading a direct employment relationship with one corporation and a connection between her work and the others.

Villafañe-Colon v. B Open Enterprises, Inc. · filed 2013-03-26(b)

Because plaintiff Villafañe has sufficiently alleged a direct employment relationship with B Open and a connection between her work for it and the other corporate defendants, a plausible inference can be made that these corporations will satisfy at least one of the tests for either a “joint” or “single” employer pursuant to the ADA and Title VII.

An entity may qualify as a joint employer under Title VII when it has sufficient control over the terms and conditions of a worker’s employment.

Kaiser v. Trofholz Technologies, Inc. · filed 2013-03-28(b)

These allegations demonstrate that while Booz Allen might not have hired Plaintiff, assigned her to a work location, received her complaints, or fired her, Booz Allen did have sufficient control, authority, and influence over the terms and conditions of Plaintiffs employment to support the contention that it was Plaintiffs joint employer with Trofholz for purposes of Title VII liability.

Section 2000e(b)’s definition of employer can cover a joint employer when the complaint plausibly alleges shared control over the worker’s employment.

St. Jean v. Orient-Express Hotels Inc. · filed 2013-08-07(b)

An employer under Title VII is “a person engaged in industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such person.” 42 U.S.C. § 2000e(b). ... Here, under either the economic realities or the immediate control test, Plaintiff has alleged facts sufficient to show that OEHI may have jointly employed her along with Cupecoy.

Section 2000e treats two entities as joint employers when they share control over essential terms and conditions of employment, including hiring, firing, pay, benefits, and supervision.

Elkin v. McHugh · filed 2014-01-07(b)

Given SERCO’s contractual requirements for hiring, firing, compensation and performance evaluation of Plaintiff as well as the Army personnel’s restricted access to information necessary to evaluate Plaintiffs work as a victim advocate, the Court concludes that the majority of the factors under the common law test for joint employer under Title VII do not favor a finding that the Army was a joint employer of the Plaintiff.

An affiliated company is not an employer under Title VII when it does not control the terms and conditions of the worker’s employment.

Baptiste v. LIDS · filed 2014-02-05(b)

Finally, plaintiff cannot show that Genesco was a “joint” employer, since there is no evidence that Genesco controlled the terms and conditions of plaintiffs employment with Hat World.

An entity may be a joint employer under Title VII when it controls workers’ tasks and how they perform them.

Equal Employment Opportunity Commission v. Global Horizons, Inc. · filed 2014-05-28(b)

In summary, when viewing the entire record in the light most favorable to the EEOC, including the Thai Claimants’ declarations and deposition testimony, the Court finds a genuine issue of material fact as to whether the Grower Defendants were joint employers under Title VII of the Thai Claimants with Global as to orchard-related matters. The evidence presented shows triable disputes of fact as to whether the Grower Defendants controlled the Thai Claimants’ work tasks and the manner to accomplish such tasks.

Title VII gives no remedy against an entity that was not the plaintiff’s employer, even if she faced discrimination or harassment at work.

Knitter v. Corvias Military Living, LLC · filed 2014-07-15(b), (f)

We hold only that to the extent Ms. Knitter faced discrimination or harassment at her job, Title VII does not furnish her with a remedy against Picerne because it was not her “employer” within the meaning of the statute.

Section 2000e permits Title VII liability against a joint employer that sufficiently controls a worker’s employment terms, particularly the challenged employment decision.

Hendon v. Kamtek, Inc. · filed 2015-07-24

Accordingly, at this stage the court will exercise jurisdiction over the action against Kamtek as Hendon’s joint-employer.

Limited supervision by an entity’s employees is insufficient to establish a joint employer relationship for Title VII liability.

Creddille v. MTA New York City Transit · filed 2015-09-30

Upon review, we conclude that the district court correctly ruled that (1) Creddille was not a Transit Authority employee, that his limited supervision by Transit Authority employees was insufficient to establish a joint employer relationship, and that the Transit Authority was therefore not subject to liability under Title VII; and (2) Creddille failed to establish that Core had subjected him to an adverse employment action in January 2011, or that there was a causal connection between his discrimination complaint with the Transit Authority and the adverse action he alleged.

Section 2000e(b)’s definition of “employer” is assessed under the hybrid test when joint employment is alleged.

Jarallah v. Thompson · filed 2015-12-21(b)

Although the district court did not apply the hybrid test for determining Title VII joint employment, see Butler v. Drive Auto. Indus., 793 F.3d 404, 408-10, 414-15 (4th Cir. 2015), the record confirms the district court’s conclusion that the institutional Defendants were not Jarallah’s “employer” under Title VII.

Section 2000e(b) permits joint employer liability based on control of the essential aspects of the employment relationship as a whole; paying wages and approving a budget alone are insufficient.

Jeff Peppers v. Cobb County, Georgia · filed 2016-08-25(b)

But, more fundamentally, Peppers’s joint employer argument founders because the focal point of the inquiry is not which entity controlled the specific aspect of the relationship giving rise to a discrimination claim, but rather which entity or entities controlled the fundamental and essential aspects of the employment relationship when taken as a whole. Whichever entity (or entities) ... predominantly controls the terms of the relationship may be found liable under Title VII.

Section 2000e(b) allows multiple entities to serve as joint employers under Title VII.

Dr. Michelle G. Scott v. Sarasota Doctors Hospital, Inc. · filed 2017-06-08(b)

We have recognized that multiple entities can serve as “joint employers” for Title VII purposes.

A client is not a joint employer under Title VII merely because it asks a contractor to remove a worker from its site.

Nischan v. Stratosphere Quality, LLC · filed 2017-08-02(b)

And this case is no dif‐ ferent: Nischan wasn’t Chrysler’s employee just because Sabbah requested and obtained her removal from the lot.

Section 2000e’s employer definition requires sufficient integration between entities to treat them as joint employers under Title VII.

High v. City Of Wylie, Texas · filed 2019-08-05(b)

Accordingly, plaintiff has not plausibly suggested that ARBH is in fact Plaintiff’s “joint employer.”

A Title VII retaliation claim against a defendant fails when that defendant is not the plaintiff’s employer.

Vaughn v. Sizemore Inc · filed 2019-11-13(b)

As stated above, the Court finds that Hyosung is not Plaintiff’s employer. Therefore, Plaintiff’s Title VII and ADA retaliation claims against Hyosung fail because those claims are premised on an employer’s conduct.

An entity qualifies as a joint employer under Title VII when it exercises significant control over the worker’s employment.

Ferrer-Marrero v. Misey Restaurant, Inc. · filed 2019-12-13(b)

“In order to qualify as an employer (or joint employer) for Title VII purposes, an entity must exercise significant control over the terms and conditions of an individual’s employment.” ... To conclude, Raíces is Ferrer’s employer for purposes of Title VII. JFY cannot be considered Ferrer’s joint employer under the statute.

An entity is a Title VII joint employer if it shares or co-determines the essential terms and conditions of a person’s employment.

Johnson v. Baptist Memorial Health Care Corporation · filed 2019-12-19(b)

The isolated facts on which Johnson relies do not raise a genuine dispute of material fact about whether BMHCC “share[d] or co-determine[d]” the “essential terms and conditions of [Johnson’s] employment.”

Under § 2000e(b), a franchisor may be a joint employer if it exercises day-to-day control over the franchisee’s employees.

Stewart v. Chick-Fil-A, Inc. · filed 2020-01-17(b)

Also, she must show the defendant meets the statutory definition of an employer, which is “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such a person....” 42 U.S.C § 2000e(b). ... Here, while Plaintiff makes conclusory allegations about Chick-fil-A being a joint employer, she does not make any specific allegations as to how Chick-fil-A exercised day-to-day control of the details of employment.

Section 2000e(f) encompasses joint employers, including a company that exercises sufficient control over a staffing agency’s worker.

Mason v. Sun Recycling, LLC. · filed 2020-03-09(f)

Applying the “hybrid test,” I find that Sun Recycling was a “joint employer.”

Providing consulting services without control over workers’ employment does not make an entity their joint employer under Title VII.

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. THE VILLAGE AT HAMILTON POINTE LLC · filed 2020-03-31(b)

The provision of these services does not create joint employment.

Section 2000e(b) allows an entity to be treated as a joint employer under Title VII when it shares control over essential employment terms; providing vehicles, workspace, and payroll services alone did not make the county an employer.

Butler v. Williams · filed 2020-05-21(b)

Ultimately, after considering the factors of the hybrid test and Plaintiff’s allegations, the Court finds that Plaintiff fails to plausibly allege that the County constitutes his “employer” under the ADA or Title VII and Plaintiff’s claims against the County must therefore fail.

A franchisor is a joint employer under Title VII only if it exercises sufficient control over the worker’s terms and conditions of employment.

ELSAYED v. FAMILY FARE LLC · filed 2020-08-10(b)

The Court need not address each of Defendants’ arguments for summary judgment because it concludes that Defendants were not Elsayed’s joint employer under Title VII.

Section 2000e(b) requires a Title VII plaintiff to show that the defendant was her employer; a company is not a joint employer when it does not control the essential terms and conditions of her employment.

Hall v. Arkema Inc · filed 2020-12-23(b)

Having considered all of the relevant factors, the Court concludes that Arkema was not Hall’s joint employer: Team was responsible for all compensation, benefits, and record keeping functions for Hall; Arkema’s supervision was limited to making sure safety rules were met and the purpose of its contract with Team was achieved; and Arkema did not set the essential terms and conditions of Hall’s employment.

Section 2000e(b) permits a separate entity to be treated as a joint employer when it has sufficient control over the employees.

Vidrine v. Broom · filed 2021-03-30(b)

Given this, Plaintiffs have failed to provide any evidence that demonstrates that the District maintained sufficient control over Plaintiffs so as to be considered a joint employer with EMS under Title VII.

Section 2000e(b) requires an entity to control the fundamental aspects of an employment relationship to qualify as a joint employer under Title VII; paying an employee’s salary alone is insufficient.

Chames v. Calhoun County Commission · filed 2021-04-14(b)

Even though the County paid Lt. Chames’ salary, it had no legal authority to control the fundamental aspects of her employment—that duty remained with Sheriff Wade.

Section 2000e(b)'s definition of employer can cover a joint employer with sufficient control over a worker's employment.

Crutchfield v. Muchowski · filed 2021-12-01(b)

Here, plaintiff has sufficiently alleged that Farmers and Muchowski were joint employers.

Section 2000e defines “employer” and “employee”; under those definitions, entities are joint employers when they share significant control of the same employee.

Felder v. USTA · filed 2022-03-07(b), (f)

Title VII defines the term “employer” to “mean[] a person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b). The term “employee” is, in turn, defined as “an individual employed by an employer.” Id. § 2000e(f). ... We will therefore find a joint employer relationship when two or more entities, according to common law principles, share significant control of the same employee.

Title VII permits a claim against a joint employer when the alleged facts make its control over the plaintiff’s employment plausible.

Nor v. Alrashid · filed 2022-03-17

But, drawing all reasonable inferences in Nor’s favor, we agree Nor’s Complaint sufficiently sets forth facts from which it is plausible Defendants can be found to be joint employers for purposes of Nor’s Title VII claims.

Section 2000e(b)’s definition of employer can include a joint employer, with control over the worker’s employment as the guiding consideration.

Bligen v. Carl Amber Brian Isaiah and Associates · filed 2022-03-22(b)

Ultimately, the Court is mindful that control is the guidepost, and after balancing all of the Butler factors, including the first three, the Court finds no merit to Plaintiff’s objections, and the Court agrees with the Magistrate Judge’s determination that CBAIA was not Plaintiff’s joint employer and therefore cannot be held liable for Plaintiff’s Title VII claims.

Allegations that an owner controlled termination and discipline can support treating him as a joint employer under § 2000e(b) at the pleading stage.

Jones v. Blair Wellness Center, LLC · filed 2022-04-11(b)

Plaintiff's Complaint thus alleges that Mr. Blair’s control over Plaintiff satisfied at least two of the “most important” factors in determining whether someone is a joint employer—ability to terminate and employee discipline.

Section 2000e permits two entities to qualify as joint employers under the hybrid economic realities/common law control test.

Mace v. Republic Health Corporation of Rockwall County · filed 2022-07-25

Accordingly, for the purposes of the Motion to Dismiss, the Court thus finds that Plaintiff has sufficiently alleged that BSW, along with Republic, were her joint employers.

Section 2000e(f) limits Title VII protection to employees, including workers whose relationship with an entity makes it their joint employer.

Parks v. Lyash · filed 2022-09-14(f)

Both Title VII and the ADEA define an “employee” as “an individual employed by an employer.” 42 U.S.C. § 2000e(f); 29 U.S.C. § 630(f). ... The undisputed evidence demonstrates that TVA was not Parks’s joint employer. See Nethery, 814 F. App’x. at 102–03. Therefore, TVA cannot be liable to Parks under Title VII or the ADEA. See 42 U.S.C. § 2000e(f); 29 U.S.C. § 630(f).

An entity may qualify as a Title VII joint employer when it shares control over aspects of an employee’s employment relationship, even if another entity is the formal employer.

Zaja v. SUNY Upstate Medical University/Upstate Healthcare Center · filed 2022-09-26(b)

Here, Defendant only references that it was not Plaintiff's official employer; it does not argue that it was not a joint employer under Title VII or did not handle any of the relevant factors identified in Shiflett. Taking all inferences in Plaintiff's favor, the Court, therefore, finds that Defendant was Plaintiff's employer pursuant to Title VII.

Under Title VII, a company using staffing agency workers may be a joint employer if it exercises significant control over their employment.

Mack v. J.M. Smucker Company, The · filed 2022-09-29(b)

Under these circumstances, the court believes a reasonable jury could only conclude that JMS was not plaintiff’s employer or joint employer.

Title VII can cover a joint employer when common-law agency factors, especially control over the worker, establish an employment relationship.

Lopez v. Weyerhaeuser Company · filed 2023-10-13

In the Ninth Circuit, the “common-law agency test” determines whether a joint employer relationship exists under Title VII. ... On this record, the Court cannot find that, as a matter of law, Weyerhaeuser is plaintiff’s joint employer, as there is no evidence that it had any involvement in the claims and allegations raised in this lawsuit.

An entity may qualify as a Title VII joint employer when it exercises sufficient control over a worker’s hiring or firing, including through a suitability decision that determines whether the direct employer can reinstate the worker.

McCoy v. MAYORKAS · filed 2023-11-22(b)

Together, these allegations are enough to raise an inference that DHS exercised sufficient influence over both McCoy’s hiring and firing and, thus, sufficient control over McCoy to be considered his joint employer.

A Title VII claim against an alleged integrated or joint employer requires facts showing that relationship or the entity’s involvement in the discrimination.

Lewis v. Ports America Chesapeake, LLC. · filed 2024-03-07(b)

Because Lewis has not provided any facts to establish that STA and Ports America were integrated or joint employers and Lewis has not separately alleged any facts alleging that STA was involved in the alleged discrimination, Lewis’ remaining claims against STA must be dismissed without prejudice for failure to state a claim.

A staffing agency’s client must plausibly function as the worker’s joint employer to face a Title VII claim.

Omotoye v. Td Bank · filed 2024-03-12(b)

Weighing all the factors, the Court concludes that Omotoye has not plausibly alleged that TD Bank functioned as his joint employer.

An entity may be treated as a joint employer under Title VII when the pleaded facts sufficiently support that relationship.

LINHART v. COUNTY OF ERIE · filed 2024-03-15(b)

Based on the foregoing, therefore, the Court finds that Plaintiff has set forth sufficient allegations to show that Erie County may be considered her joint employer under Title VII at this early stage in the proceeding.

An entity qualifies as a joint employer under Title VII when it exercises significant control over the worker.

Session v. Menasha Corporation · filed 2024-04-09(b)

Based on our application of the five-factor test, Session cannot demonstrate that Menasha “exert[ed] significant control” over her to be deemed a joint employer.

Section 2000e(b) generally limits Title VII claims to employers, including entities that jointly control the terms and conditions of employment.

Gazaway v. Nelson · filed 2024-07-10(b)

Like FEHA and the ADEA, plaintiffs generally may only assert Title VII claims against their employers. See 42 U.S.C. § 2000e(b). ... For the same reasons discussed above with respect to plaintiffs’ FEHA and ADEA claims, the existing complaint’s reliance on group pleading makes it impossible for the Court to determine whether APPS can be considered a joint employer for the purposes of Title VII. The Court will therefore grant APPS’s motion to dismiss plaintiffs’ Title VII claims.

An entity can be a joint employer under Title VII when it exercises sufficient control over a worker’s employment.

Abdelaal v. Wsp Global Inc · filed 2024-08-05(b)

At this early stage of the litigation, Mr. Abdelaal has done enough to suggest that WSP is a joint employer within the meaning of Title VII.

Section 2000e(b) defines an employer; two entities are joint employers under Title VII when they share control over essential terms and conditions of employment.

Circle Bear v. Unified Gov't of Wyandotte Co./Kansas City, KS · filed 2024-12-20(b)

Title VII defines an employer as "a person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person." 42 U.S.C. § 2000e(b). ... Under this test, courts will consider two entities to be joint employers if they "'share or co-determine'" the "'essential terms and conditions of employment.'" 758 F.3d at 1226. ... We agree with the district court that the Unified Government cannot be Circle Bear's joint employer as a matter of law.

Section 2000e’s employer definition can cover entities that jointly control the essential terms and conditions of employment.

Peck v. Schlage Lock Company, LLC · filed 2025-04-17(b)

Here, plaintiff has presented evidence that Schlage and Allegion are joint employers because (1) Allegion directed plaintiff’s work and the rules under which she worked, (2) Allegion set the conditions of plaintiff’s employment, (3) Allegion supervised and conducted plaintiff’s day-to-day activities and had the ability to discipline plaintiff, (4) Allegion controlled plaintiff’s records such as payroll, insurance and taxes and, most importantly, (5) Allegion employees terminated plaintiff’s employment.

Section 2000e’s employer definition can cover separate entities as joint employers when one retains sufficient control over the other’s employees’ terms and conditions of employment.

Williams v. The City of Daytona Beach · filed 2025-07-24(b)

Second, the “joint employer” test applies “where two entities contract with each other for the performance of some task, and one company retains sufficient control over the terms and conditions of employment of the other company’s employees.” ... Plaintiff alleges that the city exercised oversight and control over, and shared labor control with, the housing authority, (id. at 2–3), which the court accepts as true and construes in the light most favorable to her, see Henley, 945 F.3d at 1326.

Section 2000e permits Title VII liability against a joint employer when the defendant exercises sufficient control over the plaintiff’s employment.

Bolden · filed 2026-03-17(b)

Here, Bolden’s complaint neither advances a joint employer liability theory nor alleges facts to support it.

Section 2000e(b) can cover a joint employer when it exercises sufficient control over a worker; providing hospital facilities and general clinical oversight does not alone establish that relationship.

Austin v. INOVA Health Care Services · filed 2026-03-03(b)

But “multiple entities may simultaneously be considered” an individual’s employer for purposes of Title VII under the “joint employment doctrine” adopted by this Court. ... Considering all nine Butler factors together, we agree with the district court that Hoffman and Austin have not plausibly alleged Inova was their employer.

Section 2000e’s employer definition permits joint employment when an entity exercises sufficient control over a worker; the nine-factor analysis determines whether that relationship exists.

Hoffman v. INOVA Health Care Services · filed 2026-03-03(b)

This Court uses a nine-factor test to determine “which entities actually exercise control over an employee” such that they can rightly be considered an employer under Title VII.

Section 2000e’s definition of employer can encompass two entities that share significant control over an employee’s hiring, firing, or discipline.

Glenn · filed 2026-03-30(b)

Because “the common law of agency governs the meaning of ‘employer’ and ‘employee’ in Title VII,” id. at 843 (citation omitted), “a joint employer relationship [exists] when two or more entities, according to common law principles, share significant control of the same employee.” Id. (citations omitted) (emphasis in original). ... Because Mr. Glenn has alleged that New London and Kelly shared control over his “hiring, firing, . . . [and] discipline,” he has sufficiently alleged joint employer liability.

Section 2000e(a) includes governments in its definition of “person,” allowing a state to sue under Title VII.

Equal Employment Opportunity Commission v. Federal Express Corp. · filed 2003-06-17(a)

A related provision defines the word “person” to include “governments,” “government agencies,” and “political subdivisions.” 42 U.S.C. § 2000e(a). When read together, these provisions clearly authorize the State of New York, as a “government,” to bring suit under Title VII.

Section 2000e(a) includes a state human rights agency within Title VII’s definition of a person.

Morales v. Human Rights Division · filed 1995-02-21(a)

The Division is a “person” within the meaning of Section 701(a) of Title VII, 42 U.S.C. Section 2000e(a).

Section 2000e(a)'s definition of “person” excludes a hospital name that has no separate legal existence.

Carter v. Lutheran Medical Center · filed 1995-03-15(a)

Alternatively, LMC is not a "person" within the meaning of Title VII because it does not have an existence and it does not fit within the definition of "person" found in 42 U.S.C. § 2000e(a).

Section 2000e defines “person” to include units of government, a definition the ADA incorporates when defining employers.

Erickson, Melinda v. Bd Governors State · filed 2000-03-27(a)

By incorporating 42 U.S.C. sec.2000e, the ADA defines persons, and thus employers, to include units of government.

Section 2000e(a) defines “person” to include governments and governmental agencies.

Root v. Georgia State Board of Veterinary Medicine · filed 2000-08-17(a)

In the Civil Rights Act, the definition of person includes governments and governmental agencies.

Section 2000e(a) includes governments and governmental agencies in the definition of “person” that the ADA uses to define covered employers.

Hanson v. State of Oregon, Legislative Assembly · filed 2021-08-30(a)

Further, the term “person” shall “have the same meaning given such term[] in section 2000e of this title.” 42 U.S.C. § 12111(7). Section 2000e provides that the term “person” includes, among others, “one or more individuals, governments, governmental agencies, [and] political subdivisions.” 42 U.S.C. § 2000e(a) (emphasis added).

Title VII defines “person” to include governments, governmental agencies, and political subdivisions, so a municipal liability argument under § 1983 does not apply to a Title VII claim.

Sims v. City of Homewood, Alabama · filed 2024-02-16(a)

But the City makes one argument about municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978) that applies only to Count Two. (See doc. 56 at 32–36); compare Monell, 436 U.S. at 691 (considering whether a municipality is a “person” under § 1983), with 42 U.S.C. § 2000e(a) (including “governments, governmental agencies, [and] political subdivisions” in its definition of “person” under Title VII).

Section 2000e(a) includes governments, governmental agencies, and political subdivisions in Title VII's definition of “person.”

Crum v. State of Alabama · filed 1999-12-29(a)

In 1972, the statute was amended to include "governments, governmental agencies, [and] political subdivisions." 42 U.S.C. § 2000e(a). ... Given this clear precedential guidance, we have no hesitation in concluding that Congress unequivocally expressed its intent to abrogate the states' Eleventh Amendment immunity when it amended Title VII to cover state and local governments.

Section 2000e(a) defines “person” to include labor unions, a definition the ADA uses for retaliation claims.

Gaines v. New York City Transit Authority · filed 2007-12-18(a)

A union may be liable for retaliation in violation of the ADA. See 42 U.S.C. § 12203(a) (“No person shall discriminate against any individual because such individual has opposed any act or practice made unlawful by [the ADA] or because such individual made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under [the ADA].”); 42 U.S.C. § 12111(7) (“The term[ ] ‘person’ ... shall have the same meaning given such terms in ... [42 U.S.C.2000e].”); 42 U.S.C. § 2000e(a) (“The term ‘person’ includes ... labor unions”).

Section 2000e(a) includes governments and government agencies in its definition of “person.”

DAVENPORT v. NEW JERSEY BOARD OF PUBLIC UTILITIES · filed 2019-06-11(a)

Although Title VII abrogated the States’ sovereign immunity, so Plaintiff may proceed on this claim in this regard, see Title VII, § 2000e(a) (defining “person” as, among others, governments and government agencies); Fitzpatrick v. Bitzer, 427 U.S. 445, 453–57 (1976) (holding that “express congressional authority” abrogated the States’ immunity for Title VII claims), § 1983 did not create such an effect, see, e.g., King v. Board of Education, 1997 U.S. Dist. LEXIS 22820, at *88 (D. Md. May 30, 1997) (refusing to interpret § 2000d-7 as a “sweeping alteration to § 1983”).

At the pleading stage, an allegation that a supervisor committed the sexual harassment satisfies the fifth element of a sexual harassment claim.

Cooper v. Baltimore Gas and Electric Company · filed 2024-08-16(b)

As to the fifth element, Plaintiff alleges that the sexual harassment was committed by Roberts, her supervisor; therefore, the fifth element is satisfied.

An employee qualifies as a supervisor for employer vicarious liability only if the employee has significant control over employment decisions affecting subordinates.

Browne v. Signal Mountain Nursery, L.P. · filed 2003-09-29(b)

In summary, an employee does not qualify as a “supervisor” for purposes of Title VII employer vicarious liability unless he or she is placed by the employer, formally or informally, in a position of superior authority and possesses some significant degree of control over the hiring, firing, demotion, promotion, transfer, or discipline of subordinates.

Section 2000e(b) permits employer liability for an agent’s harassment, but the agent’s conduct does not make the employer automatically liable; the plaintiff must also prove a failure to take prompt remedial action.

Sims v. Brown & Root Industrial Services, Inc. · filed 1995-06-12(b)

Sims misapprehends the nature of this analysis to be that an employer is always Hable for the acts of its agents, when, in fact, it is correct to state that agency theory is only a mechanism — showing employer knowledge — which opens the door to employer HabiHty. This door will quickly shut if the plaintiff cannot prove that the employer also failed to take prompt remedial action.

Section 2000e(b) makes an employer liable under Title VII for the improper acts of its agents.

Grier v. Partek Industries, Inc. · filed 1995-09-13(b)

Gary Jones and Richard Howard are “agents” of defendant for Title VII purposes. Title VII imposes liability on an employer for the improper acts of its agents.

Section 2000e(b) includes an employer’s agents within the definition of employer, making the employer liable under Title VII for their improper acts.

White v. Wells Fargo Guard Services · filed 1995-09-29(b)

Roy Patton and David Hicks are “agents” of defendant for Title VII purposes. Title VII imposes liability on an employer for the improper acts of its agents. 42 U.S.C. § 2000e(b).

Section 2000e(b) includes an employer’s agents in its definition of employer, making them personally liable for Title VII violations.

Ruffino v. State Street Bank and Trust Co. · filed 1995-11-29(b)

Most simply, it denies the plain meaning of Section 2000e(b): that both employers, as entities, and their agents, as individuals, are to be bound by Title VII’s dictates.

Section 2000e(b) imputes a supervisor’s knowledge of quid pro quo sexual harassment to the employer.

Hott v. VDO Yazaki Corp. · filed 1996-04-02(b)

“where the sexual harassment is being committed by one of the employer’s supervisors, this element is automatically met because under 42 U.S.C. § 2000e(b) knowledge of the harassment is imputed to the employer through its agent-supervisor.” ... Thus, in the instant case, the alleged harassment is imputed to VDO because the harassment was allegedly committed by one of its supervisors — a Production Manager.

Section 2000e(b) includes an employer’s agents, allowing a supervisor’s discriminatory acts to be imputed to the employer when the supervisor has influence over hiring and firing.

Mertig v. Milliken & Michaels of Delaware, Inc. · filed 1996-05-01(b)

Based on a review of the record, it is clear that Travis is an agent of MMD. ... Since Travis is deemed an agent, his actions are appropriately imputed to MMD.

Section 2000e(b) requires a plaintiff alleging a hostile work environment to show that the employer or its agent is responsible; prompt and effective remedial action can negate employer liability.

Gregg v. Hay-Adams Hotel · filed 1996-09-12(b)

Even assuming Clark’s behavior amounted to the creation of a hostile working environment — though this is, indeed, disputed— plaintiff Gregg must also show that the employer or “any agent” of the employer is responsible for the creation of the hostility. 42 U.S.C. Sec. 2000e(b) (1988).

Section 2000e(b)'s inclusion of an employer's agents does not automatically make the employer liable for a supervisor's harassment outside the supervisor's delegated authority.

Mills v. Brown & Wood, Inc. · filed 1996-09-26(b)

All we have established at this point is that Brown & Wood is not liable, under the principles of agency, for the actions of its supervisor, Jones.

Section 2000e(b)’s agent language directs courts to agency principles when deciding whether an employer is liable for a supervisor’s sexual harassment.

Ellerth v. Burlington Industries, Inc. · filed 1997-01-28(b)

Notably, the Court phrased its discussion in terms of what Title VII required, implying that it was not creating a rule specific to sexual harassment cases but instead was construing the statute as a whole to require reference to agency principles. We must decide, therefore, whether Ellerth presented enough to defeat summary judgment for Burlington on the ground that agency principles themselves show that it is not liable for Slowik’s actions.

An employer can avoid liability for an employee's hostile work environment harassment by taking prompt remedial action reasonably calculated to prevent further harassment.

Knabe v. The Boury Corp · filed 1997-05-29(b)

So long as the remedy is reasonably calculated to prevent future instances of harassment, the company cannot be held liable under a negligence theory of agency.

Section 2000e(b) includes an employer’s agents in the definition of employer; additional supervisors need not remain as official-capacity defendants when other employer agents are already parties.

Segreto v. Kirschner · filed 1997-05-30(b)

An employer is defined as “a person engaged in an industry affecting commerce ... and any agent of such person.” 42 U.S.C. § 2000e(b). ... Thus, to the extent plaintiff seeks to state a cause of action under Title VII against his employer, it is unnecessary for the Court to determine if Rival and Callahan were “agents” of the employer under Title VII; and their continuation in the case in their official capacities under Title VII is unnecessary also.

Section 2000e(b) imputes an agent-supervisor's knowledge of sexual harassment to the employer.

Kidwell v. Sheetz, Inc. · filed 1997-09-15(b)

Under 42 U.S.C. § 2000e(b), knowledge of sexual harassment, if any, "is imputed to the employer through its agent-supervisor."

Section 2000e(b) includes an employer’s agents, so harassment reported to a supervisor with authority over the employee can put the employer on actual notice and trigger a duty to respond.

Adler v. Wal-Mart Stores, Inc. · filed 1998-05-18(b)

Mr. Larson was a low-level supervisor, but also a management-level employee for our purposes because he was titled “supervisor” and had some authority over Plaintiff, and many of her coworkers, and reported to Mr. Kirchmeier. ... Thus, the incidents of which Plaintiff told either Mr. Kirchmeier or Mr. Larson, or both, put Wal-Mart on actual notice and triggered Wal-Mart’s obligation to respond.

Section 2000e(b)’s reference to an employer’s agents does not make those agents individually liable under Title VII.

Moss v. W & a CLEANERS · filed 2000-04-27(b)

Namely, as discussed in the preceding section, Title VII claims against an employer’s agents are inappropriate because agents are not “employers” within the meaning of Title VII.

Section 2000e(b) treats an employee as an employer’s agent when the employee acts in a managerial capacity and within the scope of employment.

Garza v. Prestige Ford · filed 2001-09-26(b)

Agency in the Title VII context requires that, for an employee’s action to be imputed to an employer, the employee must be acting in a managerial capacity and in the scope of employment when committing the wrong.

Section 2000e(b) includes an employer's agents in the definition of employer; when supervisor harassment causes a constructive discharge without an official act, the employer may raise an affirmative defense to vicarious liability.

Pennsylvania State Police v. Suders · filed 2004-06-14(b)

Setting out a framework for employer liability in those decisions, this Court noted that Title VII's definition of "employer" includes the employer's "agent[s]," 42 U. S. C. § 2000e(b). See Ellerth, 524 U. S., at 754. We viewed that definition as a direction to "interpret Title VII based on agency principles." Ibid. ... But when an official act does not underlie the constructive discharge, the Ellerth and Faragher analysis, we here hold, calls for extension of the affirmative defense to the employer.

Section 2000e(b) treats supervisors as employer agents, but a worker who cannot control the plaintiffs’ employment or daily assignments is not a supervisor for vicarious liability purposes.

Martinez v. Pavex Corp. · filed 2006-03-22(b)

In the context of Title VII, a supervisor is generally considered an “agent” of the employer. ... Accordingly, Hill cannot be considered a supervisor for vicarious liability purposes.

An employer can face Title VII liability for a person functioning as its agent in decisions affecting a worker’s employment.

Zhao v. State University of New York · filed 2007-01-09(b)

Given such evidence, this Court cannot conclude as a matter of law that Dr. Batu-man was not functioning as an agent of the Research Foundation as it related to Dr. Zhao’s employment conditions and the termination decision regarding Dr. Zhao. Accordingly, the Research Foundation’s request for summary judgment on that ground is denied.

Section 2000e(b) imputes an employer’s agent’s liability to the employer rather than making the agent individually liable.

Jenkins v. Jackson · filed 2008-03-10(b)

Although 42 U.S.C. § 2000e(b) does allow suit to be brought against agents of employers, that provision merely imputes liability from the agent to the employer.

Section 2000e(b) makes employers liable under Title VII for the acts of their agents.

Williamson v. American National Insurance Company · filed 2010-03-02(b)

The purpose of the "agent” provision in § 2000e(b) was to incorporate respondeat superior liability into Title VII.

Section 2000e(b)’s employer definition does not make an affiliated company liable under Title VII merely because it shares management personnel with the employee’s employer.

Nieman v. Nationwide Mutual Insurance · filed 2010-04-08(b)

His allegations of shared management personnel are insufficient to state a claim for affiliate liability under Title VII.

Section 2000e(b) imputes a supervisor’s sexual harassment to the employer.

Pitter v. COMMUNITY IMAGING PARTNERS, INC. · filed 2010-08-18(b)

As a female, Plaintiff is a member of a protected group; the harassment she alleges is based on sex; and, pursuant to 42 U.S.C. ... § 2000e(b), any harassment perpetrated by a supervisor, such as Mr. Martinez, is automatically imputed to the employer.

Section 2000e(b) includes an employer’s agents in the definition of “employer,” making agency principles relevant to an employer’s liability for an employee’s discrimination.

Vicino v. Maryland · filed 2013-11-08(b)

Title VII further defines “employer” as “a person engaged in an industry affecting commerce ... and any agent of such a person.” 42 U.S.C. § 2000e(b) (emphasis added). Thus, agency principles guide courts when deciding whether or not to make an employer vicariously liable for the discriminatory acts and motivations of an employee.

Section 2000e(b) defines an employer for Title VII; when the complaint identifies only the university as the plaintiff’s employer, its board is not a separate employer defendant.

Frett v. Howard University · filed 2014-03-10(b)

Fortunately, I need not wade into plaintiffs strained lines of reasoning because her own complaint identifies only one “employer”: Howard University.

Section 2000e(b) includes an employer’s agents in the definition of “employer”; an employer may be liable for a supervisor’s employment decisions when the supervisor is its agent with respect to the employee’s employment status.

Brandon v. Sage Corporation · filed 2015-12-14(b)

Title VII defines “employer” to include “any agent” of the defendant company. ... We conclude that Sage is not vicariously liable because the record does not create a fact issue suggesting that Campanian was an agent with regard to Brandon’s employment status.

Section 2000e(b) permits a university to be liable for a student athlete’s discriminatory intent when the university controls the student’s conduct and negligently gives effect to that intent.

Menaker v. Hofstra Univ. · filed 2019-08-15(b)

Accordingly, the discriminatory intent of a student‐athlete may also be imputed to a university where that university exercises a “high degree of control over the behavior” of the student‐athlete and negligently permits her discriminatory conduct or effectuates her discriminatory intent.

Section 2000e(b) limits Title VII liability to employers; individual coworkers, supervisors, and managers are not personally liable.

Kolcu v. Verizon Communications Inc · filed 2024-02-01(b)

Only an employer is liable under Title VII or Title I of the ADA, Gastineau v. Fleet Mortg. Corp., 137 F.3d 490, 493 (7th Cir. 1998); 42 U.S.C. § 2000e(b), and Kolcu has adequately alleged that only Verizon Communications, Inc. was his employer.

Section 2000e(b)’s inclusion of an employer’s agents does not make those agents individually liable under Title VII.

Gibbons v. Brookside Properties, Inc. · filed 2024-08-09(b)

Additionally, although Title VII’s statutory definition of employer includes “any agent” of an employer, the Fifth Circuit has held that this language does not impose individual liability on agents. ... Accordingly, Shannon Holliman, Raymond McRaney, and Kelvin Yawn are not liable under Title VII, and the claims against them are dismissed.

Section 2000e(b) permits harassment by a supervisor to be imputed to the employer.

McDaniel · filed 2026-02-11(b)

The plaintiff sufficiently pleads that he experienced unwelcome conduct;16 and, pursuant to 42 U.S.C. § 2000e(b), any ... harassment perpetrated by a supervisor, such as Barclift, Radich, and Marshall,17 is imputable to the employer.

Section 2000e(b) includes an employer’s agents in the definition of employer, permitting direct liability for hostile environment harassment when the harasser acts as the employer’s agent.

Faragher v. City of Boca Raton · filed 1996-02-08(b)

From Congress's decision to define "employer" under Title VII to include the employer's agents, 42 U.S.C. § 2000e(b), however, the Court inferred that Congress intended for courts to look to common law agency principles in Title VII sexual harassment cases. ... The district court correctly reconciled this precedent in holding that an employer may be liable in a hostile environment case if either (1) the employer knew or should have known of the harassment and failed to take prompt remedial action, or (2) the harasser acted as the employer's agent.

Section 2000e(b)'s definition of employer supports negligence liability for a supervisor's hostile-environment harassment and strict liability for quid pro quo harassment, even when a threat produces no company act.

Jansen v. Packaging Corporation of America · filed 1997-08-12(b)

In the meantime, it is important for the district courts of this circuit to recognize in this welter of opinions that certain views do command a majority within our court: in particular, that the standard for employer liability in cases of hostile-environment sexual harassment by a supervisory employee is negligence, not strict liability, and that liability for quid pro quo harassment is strict even if the supervisor's threat does not result in a company act.

Section 2000e(b) includes an employer’s agents in the definition of “employer,” allowing a supervisor’s employment decision to be imputed to the employer when the supervisor has broad authority over hiring, discipline, and dismissal.

Craig v. Y & Y Snacks, Inc. · filed 1983-11-07(b)

Furthermore, when a supervisor who has plenary authority over hiring, discipline and dismissal makes an employment decision, that decision.may be imputed to the employer. Title VII itself defines “employer” to include “any agent of such a person.” 42 U.S.C. § 2000e(b).

Section 2000e(b) includes an employer’s agents in the definition of employer; disputed knowledge of supervisory harassment can preclude summary judgment on employer and supervisory liability.

Laughinghouse v. Risser · filed 1990-12-18(b)

The court’s review of the record reveals once again that summary judgment cannot be awarded to defendants Credithrift and Lindstrom on the issue of employer and supervisory liability. The knowledge of defendants Credithrift and Lindstrom concerning the harassment of the plaintiff remains in dispute. Accordingly, summary judgment on this issue must also be denied.

Section 2000e(b) defines an employer to include its agents, allowing an agent’s discriminatory conduct to be attributed to the employer.

Riley v. Massachusetts State Police · filed 2018-05-24(b)

Employer is defined as “a person engaged in an industry . . . and any agent of such person.” 42 U.S.C. § 2000e(b). Most courts have recognized that the inclusion of “any agent” language was intended to encompass the doctrine of respondeat superior into Title VII.

Section 2000e(j) does not require an employer to grant a religious accommodation that would violate state law and expose it to substantial penalties.

Barbour · filed 2025-12-16(j)

Title VII requires an employer “to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business.’” Groff v. DeJoy, 600 U.S. 447, 453–54 (2023) (quoting 42 U.S.C. § 2000e(j)). ... Northwell has demonstrated that granting Barbour her requested accommodation, an exemption from the vaccination requirement, would have imposed an “undue hardship” on its operations.

Section 2000e(j) allows an employer to deny a religious accommodation when it would create an undue hardship, including a substantial risk to patients and staff.

Miller v. Charleston Area Medical Center, Inc. · filed 2026-01-06(j)

Under Title VII, an employer need not accommodate an employee’s requested religious exemption if doing so would cause “undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... Therefore, considering the nature of Charleston Medical Center’s business and the practical effect granting Miller’s request would have had on the hospital, we agree with the district court that Charleston Medical Center demonstrated that accommodating Miller’s requested religious exemption would have caused undue hardship.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would impose undue hardship on its business.

Carlson · filed 2025-12-05(j)

Accommodating Plaintiffs in their patient-care roles would have imposed undue hardship on the City. An employer need not accommodate an employee’s religious practice if doing so would impose “undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).

Section 2000e(j) permits an employer to deny a religious accommodation when it demonstrates that the accommodation would impose undue hardship on its business.

Flickinger v. Department of Veterans Affairs · filed 2025-09-30(j)

However, an employer may prevail on a Title VII claim if he “demonstrates that he is unable to reasonably accommodate to an employee’s … religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... However, Defendant has pointed to evidence that Plaintiff’s refusal to be vaccinated or tested for COVID-19 created an undue hardship.

Section 2000e(j) includes religious observance and practice within religion, but an employer need not grant an accommodation that would require it to violate state law.

Cooper · filed 2025-09-18(j)

Plaintiff's failure-to-accommodate claim must be dismissed because her requested exemption from the Vaccine Policy would have required Defendants to violate the law.

An employer can establish undue hardship from a religious accommodation by showing that its health and safety risks, staffing challenges, and administrative burdens would substantially burden its operations.

Pound v. Benton County Health Department · filed 2025-09-19(j)

In sum, Defendant’s evidence is sufficient to establish that its operations would have suffered an undue hardship if it allowed Plaintiff to continue working.

Section 2000e(j) does not require a religious accommodation that would impose an undue hardship on the employer.

RIGHTEOUS v. OVERBROOK SCHOOL FOR THE BLIND · filed 2025-02-13(j)

Overbrook has demonstrated that accommodating Plaintiffs would have presented an undue hardship, and Plaintiffs have not identified any material facts to create genuine disputes as to that conclusion.

An employee must adequately notify the employer of a request for religious accommodation to trigger the employer’s accommodation duty.

Higgins v. City and County of Denver · filed 2025-01-30(j)

In light of these facts, the Court finds that Mr. Higgins’s statement to Denver did not adequately notify Denver of a request for a religious accommodation.

Section 2000e(j) does not require an employer to grant a religious accommodation that would violate state law and expose it to penalties.

Brown v. South Shore University Hospital · filed 2025-01-10(j)

For these reasons, Brown’s sole requested accommodation, if granted, would have caused Defendants undue hardship by requiring them to violate Section 2.61. The Amended Complaint thus fails to state a Title VII religious accommodation claim.

Section 2000e(j) allows an employer to deny a religious accommodation when it would impose substantial increased costs on the business.

Davis v. Reliance Test & Technology, LLC. · filed 2025-01-22(j)

Defendant has proven that accommodating Plaintiffs’ vaccination exemptions could have risked Defendant’s contract with the government, Plaintiffs were unable to perform their jobs fully while unvaccinated, and they posed a health risk to Defendant’s other employees and government employees. This constitutes a “substantial increased costs in relation to the conduct of its particular business,” and also shows the impact of the potential accommodation on Plaintiffs’ coworkers.

Section 2000e(j) requires an employer claiming undue hardship to show that a religious accommodation would impose substantial costs in relation to its business.

Abbott v. Austal USA, LLC · filed 2025-01-03(j)

Thus, the plain language of Title VII requires something closer to “substantial additional costs” or “substantial expenditures.” Id.

Section 2000e(j) excuses an employer from accommodating an employee’s religious practice when doing so would impose an undue hardship on its business.

Efimoff v. Port of Seattle · filed 2024-11-13(j)

The “undue hardship” defense is a complete defense to WLAD and Title VII failure-to-accommodate claims.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would impose a substantial burden in the context of the employer’s business.

Kizer v. St. Jude Children's Research Hosp. · filed 2024-11-18(j)

The employer must thus show that “the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business,” meaning that the statutory requirement of “‘undue hardship’ is [met] when a burden is substantial in the overall context of an employer’s business.” See Groff v. DeJoy, 600 U.S. 447, 468, 470 (2023).

At the motion to dismiss stage, this court treated employees’ religious objections to proposed accommodations as issues bearing on the accommodations’ reasonableness.

Wilder v. Honeywell Federal Manufacturing & Technologies, LLC · filed 2024-10-24(j)

Regardless, in light of Cole, the Court finds that whether Plaintiffs had a religious objection to the accommodations themselves goes to the reasonableness of the accommodations and is not a proper consideration at the motion to dismiss stage.

Section 2000e(j) makes undue hardship a complete defense to a Title VII claim for failure to accommodate religious practice.

Slater v. Behavioral Health Resources · filed 2024-09-25(j)

Behavioral Health has shown that it is entitled to a judgment as a matter of law – the undue hardship defense is a complete defense to WLAD and Title VII failure-to-accommodate claims. See 42 U.S.C. § 2000e(j); Kumar at 501-02; Williams v. Legacy Health, 3:22-CV-6004-TMC, 2024 WL 3993162 (W.D. Wash. Aug. 29, 2024).

Section 2000e(j) requires an employer to accommodate an employee’s religious beliefs unless the employer shows that doing so would cause undue hardship.

Hewitt-Simmons v. Mayor Eric Adams · filed 2024-09-30(j)

The burden thus shifts to Defendants to show they could not accommodate Plaintiff’s beliefs without undue hardship. Defendants have yet to make any argument that accommodating Plaintiff’s objection to the vaccine mandate through measures short of termination (i.e., the consequence she alleges she faced for refusing to be vaccinated) would have caused them an undue hardship given the nature of her employment and other relevant factors at that time. Therefore, the Court denies Defendants’ motion to dismiss Plaintiff’s Title VII claim.

Section 2000e(j) permits an employer to deny a religious accommodation when any reasonable accommodation would cause undue hardship.

Mohamed v. Full Life Care · filed 2024-10-02(j)

Here, even if the Court assumes that Mohamed had set forth a prima facie case of discrimination based on a failure to accommodate, Defendants have met their burden to show that any reasonable accommodation would have caused an undue hardship.

The court held that the requested religious vaccine exemption would have imposed an undue hardship on the employer.

Hall v. Sheppard Pratt Health Systems, Inc. · filed 2024-09-20(j)

But the Court need not decide that issue, or whether Sheppard Pratt is entitled to good-faith-reliance immunity under either EEOC source, because whether measured against the Hardison or Groff articulation of “undue hardship,” the undisputed evidence establishes that granting Ms. Hall’s accommodation request would have constituted an undue hardship.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practices unless doing so would impose an undue hardship, which can include a danger of violating antidiscrimination law.

Trueblood v. Valley Cities Counseling and Consultation · filed 2024-08-28(j)

To that end, an employer must “reasonably accommodate” an employee’s religious practices unless doing so would pose an “undue hardship on the conduct of the employer’s business.” ... VCCC demonstrates undue hardship because the Disputed Accommodations would sanction discrimination against VCCC’s clients and staff and, at the very least, create a danger of violating federal and state law, exposing VCCC to potential liability as a result.

Section 2000e(j) places undue hardship in Title VII’s definition of religion, and an employer is not liable for religious discrimination if that defense applies.

Bazinet v. Beth Israel Lahey Health, Inc. · filed 2024-08-13(j)

"The undue hardship defense is built into the statutory definition of 'religion,' see 42 U.S.C. § 2000e(j), such that an employment action cannot constitute discrimination on the basis of religion, and an employer cannot be liable under Title VII for religious discrimination, if the undue hardship defense applies."

Section 2000e(j) requires employers to accommodate religious practices unless the accommodation would cause undue hardship, assessed on the facts of the employer’s business.

Dodson v. Lutheran Village at Miller's Grant · filed 2024-07-30(j)

As the Groff decision makes clear, however, undue hardship must be assessed on a case-by-case basis. ... Although Lutheran Village has moved in the alternative for summary judgment, it has not supplied any evidence to support its undue hardship defense.

Section 2000e(j) covers an accommodation request plausibly based in part on religious belief or practice, even when secular concerns also motivate it.

Dottenwhy v. Aspirus, Inc. · filed 2024-07-29(j)

But the fact that an accommodation request also invokes or, as here, even turns upon secular considerations does not negate its religious nature.

Section 2000e(j)’s religious accommodation duty requires an applicant to inform the employer of a religious belief that conflicts with a job requirement.

Muslim v. Sagamore Children's Psychiatric Center · filed 2024-07-15(j)

Plaintiff fails to satisfy the second element of his claim because he does not plead that he informed OMH of his claimed religious belief.

Section 2000e(j) requires an employer to accommodate an employee’s religious practice unless doing so would impose undue hardship; whether a reasonable alternative was available can be a question for the factfinder.

Bottman v. Springfield Public Schools · filed 2024-07-12(j)

Here, a factfinder could reasonably conclude that the District could have implemented a less burdensome alternative accommodation without unduly burdening itself.

Section 2000e(j) does not require an employer to grant a religious accommodation that would violate state law and impose undue hardship.

Rowe v. Brookdale University Hospital · filed 2024-07-17(j)

Granting the requested exemption would have imposed undue hardship on Brookdale and Plaintiff has not identified any other accommodation Brookdale could have offered her that would have permitted her to remain in her nursing position while also enabling Brookdale to comply with state law.

Section 2000e(j) does not require an employer to allow unvaccinated on-site work when doing so would violate a state vaccination rule and impose an undue hardship.

Pastor v. Mercy Medical Center · filed 2024-06-17(j)

Plaintiff’s requests that MMC allow her to work on site—i.e., her requests to undergo “masking, social distancing, and weekly or bi-weekly COVID-19 testing” (Compl., ECF No. 1 ¶¶ 12, 43)—would have imposed an undue hardship as a matter of law.

Section 2000e(j) does not require an employer to provide a religious accommodation that would impose an undue hardship.

Devita v. Mount Sinai Hospital · filed 2024-06-18(j)

The Court concludes that, based on Plaintiff’s allegations—in a twice-amended complaint—that granting a telework accommodation to a Registered Nurse would have imposed an undue hardship on Defendants.

Section 2000e(j) does not require an employer to grant a religious accommodation that would violate a state vaccination mandate, because doing so would impose an undue hardship.

Haczynska v. Mount Sinai Health System, Inc. · filed 2024-06-26(j)

Mount Sinai Defendants have sufficiently shown that granting Plaintiffs a religious exemption would have imposed an “undue hardship” on their operations.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practice unless the accommodation would cause the employer undue hardship.

French v. Albany Medical Center · filed 2024-06-12(j)

Based on the foregoing, the Court concludes that Plaintiff's requested accommodation was not reasonable as it was a blanket exemption request which would have allowed her to continue interacting with staff and vulnerable patients while unvaccinated. This exemption would have caused an undue hardship on Defendant.

Section 2000e(j) includes religious observance and practice within religion and requires employers to accommodate those practices unless doing so would impose an undue hardship.

Ramos v. Envoy Air Inc · filed 2024-05-29(j)

“The statute defines ‘religion’ broadly to include ‘all aspects of religious observance and practice, as well as belief.’”... Ramos clearly pled facts on all four elements of a prima facie case of religious discrimination, and therefore, plausibly alleged a religious discrimination claim under Title VII.

Section 2000e(j) requires employers to accommodate an employee’s religious beliefs unless doing so would impose an undue hardship.

Feds for Medical Freedom v. Austin · filed 2024-06-10(j)

Title VII requires employers to accommodate an employee’s religious beliefs unless doing so would impose an undue hardship.

Section 2000e(j) requires an employer to accommodate an employee’s religious practice unless doing so would impose an undue hardship on its business.

Isensee v. Amplity Inc · filed 2024-05-13(j)

Title VII requires an employer to accommodate an employee’s religious practice “unless doing so would impose an ‘undue hardship on the conduct of the employer’s business.’” Groff v. DeJoy, 600 U.S. 447, 468, 143 S. Ct. 2279 (2023) (quoting 42 U.S.C. § 2000e(j)); see also Tepper v. Potter, 505 F.3d 508, 514 (6th Cir. 2007). ... Consequently, a genuine dispute of material fact exists as to whether accommodating Isensee would have been an undue hardship and whether a reasonable accommodation existed.

Section 2000e(j) does not require an employer to provide a religious accommodation that would force it to violate a binding state vaccination rule.

Riley v. New York City Health & Hospitals Corporation · filed 2023-02-17(j)

The statute requires an employer to “reasonably accommodate” an employee’s “religious observance or practice,” unless doing so would impose “undue hardship on the conduct of the employer’s business.” Id. § 2000e(j). ... Granting this accommodation would cause the defendant the undue hardship of forcing it to violate Section 2.61.