42 U.S.C. § 2000e

Section 2000e(b)’s definition of employer does not make individual supervisors personally liable under Title VII.

United States v. Municipio De Vega Alta · filed 2007-05-15(b)

Section 701 of Title VII, 42 U.S.C.A. § 2000e, defines the term 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, and any agent of such a person.... ” 42 U.S.C.A. § 2000e. ... Finally, there being no individual liability under Title VII, Intervenor Plaintiffs’ Title VII claims against Colón and Rey are hereby DISMISSED WITH PREJUDICE.

Section 2000e(b) defines “employer” for Title VII, which does not impose liability on individual supervisors.

Knox v. City of Monroe · filed 2008-03-12(b)

Title VII imposes liability only on "employers” as defined by the statute.

Section 2000e’s definition of employer does not permit individual liability under Title VII.

Aque v. Home Depot U.S.A., Inc. · filed 2009-02-02(b)

It is well established that there is no individual liability under any of the three statutes. ... The court therefore ADOPTS the Magistrate Judge’s ruling that the Title VII, ADA, and ADEA claims be dismissed as against Mr. Hourigan and Ms. Longacre.

Section 2000e(b)’s definition of employer does not make individual employees personally liable under Title VII.

Fantini v. Salem State College · filed 2009-02-23(b)

Title VII defines “employer”, in relevant part, 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). ... After reviewing the analysis fashioned by all of our sister circuits, we are persuaded by their analysis and therefore take this opportunity to determine as they have that there is no individual employee liability under Title VII.

Section 2000e(b)'s definition of employer does not make agents or supervisors personally liable under Title VII.

Cintron-Alonso v. GSA Caribbean Corp. · filed 2009-03-18(b)

This Court agrees that it is settled law in this district that “... no personal liability can be attached to agents or supervisors under Title VII.”

Section 2000e(b)'s inclusion of an employer's agents does not make a supervisor separately liable under Title VII; an official-capacity claim against the supervisor merges with the claim against the employer.

Brown v. Corr. Corp. of Am. · filed 2009-03-26(b)

Although Title VII defines the term “employer” to include “any agent of’ the employer, 42 U.S.C. § 2000e(b), ... Because it is the employer alone who is liable, the claim against the employee “merges” with the claim against the employer. ... The claim against Mr. Brown, which is equivalent to and merges with the claim against the District, will be dismissed because it is duplicative of the claim against the District.

Section 2000e(b)’s definition of employer does not make individual employees personally liable under Title VII.

Maldonado v. Hospital Alejandro Otero Lopez · filed 2009-03-31(b)

Pursuant to Title VII, the term “employer” means, in relevant part, “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). ... Consequently, there being no individual employee liability under Title VII, we therefore GRANT the defendants’ request to dismiss Plaintiffs Title VII claims against individual employee defendants Paravisini and Disdier.

Section 2000e’s definition of employer does not make individual supervisors personally liable under Title VII.

St. Louis v. New York City Health & Hospital Corp. · filed 2010-02-01(b)

It is well settled that unlike employers, “individuals are not subject to liability under Title VII.” ... Accordingly, to the extent Plaintiff asserts Title VII claims against defendants Sylvester and Moorhead, those claims are dismissed.

Section 2000e’s definition of employer does not permit Title VII damages claims against public officials in their individual capacities.

Fraker v. MARYSVILLE EXEMPTED VILLAGE SCHOOLS · filed 2010-03-08(b)

Moreover, Title VII, 42 U.S.C. § 2000e, et seq., does not authorize an action for money damages against a person in his or her individual capacity.

Section 2000e(b) includes an employer’s agents in the definition of “employer,” but does not permit a separate Title VII suit against an individual agent when the employer is also sued.

Montgomery v. SEARS ROEBUCK & CO. · filed 2010-06-17(b)

“Employer” is defined in Title VII as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day ... and any agent of such a person.... ” 42 U.S.C. § 2000e(b). ... However, a suit against an employer’s agent is actually a suit against the employer under Title VII, and “a party may not maintain a suit against both an employer and its agent under Title VII.” ... Gewin and Sears’ Motion for Summary Judgment on Montgomery’s remaining claims against Gewin is GRANTED.

Section 2000e(b)'s definition of employer does not make a supervisor personally liable under Title VII when the supervisor is the plaintiff's co-employee.

Patterson v. Xerox Corporation · filed 2010-08-02(b)

To the extent that Title VII claims are asserted against Peterson, those claims must be dismissed because his status is Plaintiffs co-employee, not her employer.

Section 2000e(b) defines an employer to include certain agents, but employees and supervisors who do not otherwise qualify as employers cannot be held personally liable under Title VII.

Smith v. Board of Trustees Lakeland Community College · filed 2010-09-28(b)

The statute defines an employer as “a person engaged in an industry affecting commerce who has fifteen or more employees ... and any agent of such person.” 42 U.S.C. § 2000e. ... It is well-established in the Sixth Circuit that an individual employee or supervisor who does not otherwise qualify as an employer cannot be held personally or individually liable under Title VII. ... Accordingly, Smith’s Title VII claims against the Individual Defendants in their personal capacities are DISMISSED with prejudice.

Section 2000e(b) defines “employer” in a way that excludes individual employees and supervisors who do not themselves employ the plaintiff from Title VII liability.

Esaka v. NANTICOKE HEALTH SERVICES, INC. · filed 2010-11-23(b)

The court is therefore satisfied that there is no basis for individual liability against Crockett or Stokes, and will grant their motion to dismiss all Title VII claims against them.

Section 2000e(b)’s definition of employer excludes individual employees and supervisors from personal liability for damages under Title VII.

Clemmons v. Hawaii Medical Services Ass'n · filed 2011-01-28(b)

Defendants argue that Kent should be dismissed from the suit because she has no personal liability under Title VII, the only basis on which she is sued. The court agrees. The Ninth Circuit ruled nearly twenty years ago that individuals may not be sued for damages under Title VII.

An employee or supervisor who does not qualify as an employer cannot be held personally liable for discrimination under Title VII.

Adamov v. U.S. Bank National Ass'n · filed 2011-03-07(b)

In Wathen v. General Elec. Co., 115 F.3d 400, 405 (6th Cir.1997), the United States Court of Appeals for the Sixth Circuit stated, “[A]n individual employee/supervisor, who does not otherwise qualify as an ‘employer,’ may not be held personally liable under Title VII.” To the extent that Adamov seeks to hold Hartnack individually liable for discrimination, the claims must be dismissed.

Section 2000e(b) includes an employer’s agents in the definition of employer, but does not make supervisors or coworkers personally liable under Title VII.

Brown v. Children's National Medical Center · filed 2011-03-30(b)

An employer is defined under Title VII 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). ... Plaintiffs Title VII claims against Singh, MorrisonQuintana, Hulbert and Koepenick in their individual capacities therefore must be dismissed.

Title VII does not impose individual liability on supervisors.

Rey-Cruz v. Forensic Science Institute · filed 2011-05-16(b)

Finding that there is no individual liability under Title VII or the ADA, the Court does not need to examine the individual Defendants’ claims of qualified immunity.

Section 2000e(b) defines “employer”; individual employees are not personally liable under Title VII.

Garcia v. Newtown Township · filed 2011-06-10(b)

"Employer” is defined under Title VII 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, and any agent of such person ...” 42 U.S.C. § 2000e(b). ... Individual employees may not be held liable under Title VII, ... In light of this, we are required to enter summary judgment in favor of Mr. Czajkowski on Plaintiff’s claims under Title VII.

Section 2000e(b)'s definition of employer does not make individual employees personally liable under Title VII.

Román v. University of Puerto Rico · filed 2011-07-27(b)

The case law dictates that the Individual Defendants cannot be held liable for a cause of action under Title VII, as Title VII does not provide for individual liability.

Section 2000e(b)’s definition of employer excludes individual supervisors and fellow employees from Title VII liability.

Umoren v. Plano Independent School District · filed 2012-01-06(b)

Umoren’s Title VII claims against the Individual Defendants were properly dismissed because “relief under Title VII is only available against an employer, not an individual supervisor or fellow employee.” Foley v. Univ. of Houston Sys., 355 F.3d 333, 340 n. 8 (5th Cir. 2003)(citing 42 U.S.C. § 2000e(b)’s definition of “employer”).

An individual employee who does not qualify as an employer cannot be held personally liable under Title VII, including for retaliation.

Yedes v. Oberlin College · filed 2012-03-23(b)

The law is clear in the Sixth Circuit that an individual employee, who does not qualify as an employer within the meaning of Title VII, may not be held personally liable under Title VII. ... However, Plaintiffs retaliation claim is brought under Title VII and does not survive the bar against individual liability recognized in Wathen. Accordingly, Defendant Senior’s Motion for Summary Judgment on all of Plaintiffs claims under Title VII is granted.

Section 2000e(b)’s reference to an employer’s agent incorporates respondeat superior liability but does not make the agent individually liable under Title VII.

Muthukumar v. Kiel · filed 2012-05-30(b)

This section also references “any agent” of an employer, but that term merely incorporates the principle of respondeat superior liability into Title VII. ... No individual liability by the agent results, though.

Section 2000e’s definition of employer does not make individual employees liable under Title VII.

Shuler v. Board of Trustees of the University of Alabama · filed 2012-07-03(b)

The individual defendants are not “employers” under Title VII, and thus Shuler’s claim against them fails.

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

Chu v. Mississippi State University · filed 2012-10-03(b)

The “agent” provision instead incorporates respondeat superior liability into the statute.

Supervisors in their individual capacities are not employers under Title VII and cannot be sued under it.

Bogie v. Paws Chicago · filed 2012-11-15(b)

The defendants are correct that supervisors, in their individual capacity, are not “employers” under Title VII, and thus are not susceptible to suit under Title VII.

Section 2000e(b)’s inclusion of an employer’s agents does not permit a Title VII claim against both the employer and its agents or employees.

Franklin v. City of Slidell · filed 2013-03-06(b)

However, whether Dr. Klein acted as the City’s “agent,” for purposes of Title VII, in performing the allegedly retaliatory fitness for duty evaluation is immaterial, because a plaintiff may not maintain a Title VII claim against both his employer and the agents or employees of his employer.

An employee or supervisor who does not independently qualify as an employer cannot be held personally liable under Title VII.

Ivey v. McCreary County Fiscal Court · filed 2013-03-29(b)

(1) Defendants’ Motion to Dismiss [R. 7] is GRANTED with respect to the claims made against Jimmy Barnett in his individual capacity under KRS § 337, KRS § 61, Title VII, and the KCRA with the exception of the claim for retaliation under KRS 344.280.

Section 2000e(b)’s definition of employer does not make an individual supervisor personally liable under Title VII.

Fife v. Vicksburg Healthcare, LLC · filed 2013-05-13(b)

As an initial matter, the Court finds that Plaintiffs Title VII and ADEA claims against Defendant Darlene White fail as a matter of law. Neither statute allows a plaintiff to maintain a claim against an individual supervisor.

Section 2000e(b)’s definition of employer permits a qualifying supervisor to be sued under Title VII only in an official capacity, not a personal capacity.

Hunt v. Central Consolidated School District · filed 2013-06-12(b)

While an individual employee “who serves in a supervisory position and exercises significant control over the plaintiff’s hiring, firing or conditions of employment,” may qualify as an employer for Title VII purposes, because “the individual operates as the alter ego of the employer,” a plaintiff can only sue that individual in his or her official capacity.

Section 2000e’s employer definition does not make supervisors or coworkers personally liable under Title VII.

Bonenberger v. St. Louis Metropolitan Police Department · filed 2013-07-08(b)

Title VII, unlike the other statutes, does not authorize liability against individual supervisors or coworkers.

Section 2000e’s definition of employer does not make individual employees personally liable under Title VII.

Warshun v. New York Community Bancorp, Inc. · filed 2013-08-01(b)

In addition, the Court dismisses the federal antidiscrimination claims with prejudice because even if the Individual Defendants were properly served, Title VII and the ANEA, do not provide for individual liability; rather, only against the employer.

Section 2000e(b)'s definition of employer does not make an individual supervisor liable under Title VII, even when the supervisor is sued in an official capacity.

Gretzula v. Camden County Technical Schools Board of Education · filed 2013-08-14(b)

Although there is conflicting precedent, the Court holds that Plaintiff cannot bring a Title VII claim against Monillas in his official capacity. The reasoning is persuasive in the cases dismissing official capacity claims against individual defendants who are not themselves employers. Title VII provides for liability against employers, not supervisors.

Section 2000e(b)'s definition of “employer” does not make individual supervisors liable under Title VII merely because they act as an employer's agents.

Minnis v. Board of Supervisors of Louisiana State University & Agricultural & Mechanical College · filed 2013-09-18(b)

Here, the Administrator Defendants do not meet the definition of “employer” under Title VII. Minnis may proceed with his Title VII claims against LSU, but the individual defendants are not liable under Title VII. Accordingly, Defendants’ motion to dismiss Minnis’s Title VII claims against the individual defendants is GRANTED.

Section 2000e’s definition of “employer” excludes individual supervisors, managers, and co-workers from Title VII liability.

Han v. University of Dayton · filed 2013-11-05(b)

Title VII does not allow for liability on the part of any person or entity other than Plaintiffs “employer.” And according to this Court, under 42 U.S.C. § 2000e, an “employer” does not include the “supervisors,” “managers,” or “co-workers” of a plaintiff.

Section 2000e’s definition of employer does not make supervisory employees individually liable for Title VII violations merely because they act as agents of an employer.

Jones v. Ottenberg's Bakers, Inc. · filed 2013-11-21(b)

But “Title VII does not impose individual liability on supervisory employees.”

Section 2000e(b)’s definition of employer does not make individual employees personally liable under Title VII.

Ellorin v. Applied Finishing, Inc. · filed 2014-02-07(b)

Thus, as a matter of law, Ms. Ellorin is barred from asserting any claim under Title VII against Mr. Soden.

Section 2000e(b) does not impose individual liability on employees or supervisors who do not qualify as employers.

Minevich v. Spectrum Health-Meier Heart Center · filed 2014-03-06(b)

Because Defendants Elmouchi, Beekman, and Green are not “employers” as defined by Title VII, 42 U.S.C. § 2000e(b), summary judgment is GRANTED in their favor.

Section 2000e’s definition of employer does not make supervisors individually liable under Title VII.

Russell v. Russel Motor Cars Inc. · filed 2014-06-18(b)

Neither of these sources displaces the rule adopted by the Fourth Circuit, and therefore it is apparent that Russell cannot maintain a suit against Butler, Herd, or Ryland under Title VII.

Section 2000e(b)’s definition of “employer” does not make a supervisor individually liable under Title VII when the supervisor does not otherwise qualify as an employer.

Giles v. Hometown Folks, LLC · filed 2014-10-14(b)

“Employer” is defined 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). Although Title VII does not define “any agent,” the Sixth Circuit has declined to impose individual liability on supervisors. Wathen v. Gen. Elec. Co., 115 F.3d 400, 405-06 (6th Cir.1997) (finding that “an individual employee/supervisor, who does not otherwise qualify as an ‘employer,’ may not be held personally liable under Title VII”). Given the plaintiffs allegations and the undisputed facts in the record regarding Bealer’s position, the Court finds Bealer is not an “employer” under Title VII and thus cannot be held liable under Title VII.

Individual supervisors are not employers under Title VII and cannot be held personally liable under it.

Patrick v. Garlick · filed 2014-12-04(b)

Initially, the Court agrees with Garlick that he is entitled to the dismissal of plaintiffs’ Title VII claims against him. It is well settled that individuals are not amenable to suit under Title VII.

Section 2000e(b)’s definition of employer excludes individual supervisors from Title VII liability.

Jones v. Kroger Ltd. Partnership I · filed 2015-01-13(b)

Title VII provides that employers with more than fifteen employees may not discriminate against an employee on the basis of sex or other protected traits. ... It is well-settled, however, that individual supervisors like Townsend cannot be held liable for Title VII violations. ... The court will therefore dismiss the Title VII claim against Townsend, and Count II will proceed as a Title VII sexual harassment claim against Kroger only.

Section 2000e’s definition of employer does not make individuals personally liable for Title VII violations.

Figueroa v. RSquared NY, Inc. · filed 2015-03-03(b)

Individual defendants may not be held personally liable for alleged violations of Title VII.

Section 2000e(b) defines covered employers; individual employees who are not employers cannot be personally liable under Title VII.

DeSantis v. New Jersey Transit · filed 2015-04-29(b)

Count Four, the Title VII claim, must be dismissed as against Wohl and D’Ascoli, because they are not employers but individuals.

Section 2000e(b) does not make individual employees liable under Title VII.

Amiri v. Securitas Security Services USA, Inc. · filed 2015-06-05(b)

The district court properly held that Title VII does not impose individual liability on the employees named as defendants.

Section 2000e(b) defines who is an employer under Title VII; individual union officers who are employees rather than employers cannot be held personally liable for retaliation.

Ciferni v. Boilermakers Local 13 · filed 2016-01-26(b)

“Employer” is defined by the statute to mean “a person.. .who has fifteen or more employees — ” 42 U.S.C. § 2000e(b). ... All of the individual defendants are employees of Local 13, and are not themselves employers for Title VII purposes.

An individual employee or supervisor who does not otherwise qualify as an employer cannot be held personally liable under Title VII.

Strong v. HMA Fentress County General Hospital, LLC · filed 2016-07-12(b)

The Sixth Circuit first “squarely addressed” this issue in Wathen v. General Electric Co., 115 F.3d 400, 405 (6th Cir.1997), and “h[e]ld that an individual employee/supervisor, who does not otherwise qualify as an ‘employer,’ may not be held personally liable under Title VII,” and that the Civil Rights Act of 1991 “contains no provision for damages to be paid by individuals, further evidencing a lack of congressional intent to hold individuals liable.” ... Accordingly, dismissal as to Crabtree is warranted with respect any claim under Title VII or the Civil Rights Act of 1991.

Section 2000e(b)’s definition of employer does not make individuals personally liable under Title VII.

Mussallihattillah v. McGinnis · filed 2017-03-27(b)

First, although the district court did not rely upon this ground in its decision, Mussallihattillah’s Title VII claims as against the individual defendants fail as a matter of law.

Exclusion from Title VII’s definition of “employee” does not make an elected official individually liable; Title VII imposes liability on employers.

Perez v. Town of North Providence · filed 2017-06-22(f)

This syllogism — Title VII does not impose liability on employees, and Mayor Lombardi is not an employee; therefore, Mayor Lombardi can be held liable under Title VII — misses the mark. Title VII only imposes liability on employers, ... so Mayor Lombardi’s lack of employee status is irrelevant.

Section 2000e(b) does not make a supervisor personally liable under Title VII unless the supervisor independently qualifies as an employer.

Woodbury v. Victory Van Lines · filed 2017-12-21(b)

Nor is Yanuzov an individual who meets the definition of an "employer" on his own. Victory is not a sole proprietorship, such that it and Yanuzov would be legally treated as one and the same. Rather, it is owned by Great Nation Moving, LLC, which makes Great Nation, not Yanuzov, Woodbury's employer. Accordingly, both the Title VII and ADA claims against Yanuzov will be dismissed.

Section 2000e(b) defines the employer for Title VII purposes; supervisors cannot be held individually liable under the statute.

Roan v. Ensminger · filed 2018-02-15(b)

More specifically, Magistrate Judge Brown found that ... (4) the discrimination claims fail because Mason (and Ensminger for that matter) cannot be held individually liable under Title VII. ... The R & R (Doc. No. 9) is ADOPTEDand APPROVEDinsofar as it recommends dismissal of all claims against Ensminger and Mason.

Section 2000e(b) defines an employer for Title VII purposes; supervisors are not individually liable for the employer’s discrimination.

Coclough v. Akal Security, Inc. · filed 2018-03-29(b)

A Title VII discrimination claim may be brought against the plaintiff’s employer. See 42 U.S.C. §§ 2000e(b), 2000e-2(a). Although a supervisor may be named a party defendant in a lawsuit under Title VII, he or she is not liable in his or her individual capacity for any discriminatory action of the employer.

Section 2000e(b)’s definition of employer excludes individual employees from Title VII liability.

Sharma v. Wesley · filed 2018-04-17(b)

Plaintiff’s complaint fails to state a claim upon which relief can be granted against the individual defendants because individuals are not subject to liability under Title VII.

Title VII’s definition of employer does not make individual supervisors liable.

Mallory v. Middle TN. Mental Health · filed 2019-06-10(b)

As an initial matter, the R&R recommends dismissal of “Ms. Thompson” as a named party because “Title VII only applies to employers and not to individual supervisors.” (ECF No. 6 at PageID 27 n.2.) Indeed, “the statute as a whole, the legislative history and the case law support the conclusion that Congress did not intend individuals to face liability under the definition of ‘employer’ it selected for Title VII.” Wathen v. Gen. Elec. Co., 115 F.3d 400, 406 (6th Cir. 1997). The Court ADOPTS the R&R as to this issue and DISMISSES “Ms. Thompson” from the case.

Section 2000e(b)’s definition of employer excludes individual employees from Title VII liability, whether sued in their individual or official capacities.

McGee v. Bossier Parish · filed 2019-06-26(b)

Individual employees cannot be held liable under Title VII in either their individual or official capacities.

Section 2000e’s definition of employer does not make individual supervisors liable under Title VII.

Erdmann v. Packaging Corporation of America · filed 2019-07-12(b)

Plaintiff’s individual supervisors cannot be sued under Title VII.

Section 2000e(b)'s definition of employer does not make a supervisor individually liable under Title VII merely because the supervisor acts as the employer's agent.

Traylor v. Southern Components Inc · filed 2019-08-01(b)

A Title VII “employer” is “a person engaged in an industry affecting commerce who has fifteen ot more employees .. . and any agent of such a person.” 42 U.S.C. § 2000e(b). Although the latter phrase could suggest individual liability, the Fifth Circuit has approvingly cited a Ninth Circuit case that concludes that the “any agent” language “incorporate[s]” respondeat superior liability into [Title VII.” Grant, 21 F.3d at 653 (citing Miller v. Maxwell’s Int'l Inc., 991 F.2d 583, 587 (9th Cir. 1993)). Because no evidence suggests that Kral personally employs anyone, he is not liable under Title VII.

Section 2000e(b)’s definition of employer does not make supervisors or other employees individually liable under Title VII.

Ricks v. Friends of WWOZ, Inc. · filed 2019-08-15(b)

Title VII applies only to “employers,” not to supervisors or other individual employees.

Section 2000e’s definition of employer does not make individual employees liable under Title VII.

Roberson v. Barretts Business Services, Inc. · filed 2019-09-04(b)

Individual employees cannot be held liable under Title VII.

Section 2000e(b)’s definition of employer does not make a supervisor individually liable under Title VII.

Sambrano v. Palmetto Heights Management LLC · filed 2019-10-22(b)

Title VII does not provide causes of actions against defendants in their individual capacities.

Section 2000e(b)’s definition of employer does not make individuals liable under Title VII.

Barnett v. Palmetto Heights Management LLC · filed 2019-10-28(b)

The Fourth Circuit has analyzed the definition of “employer” and rejected the notion of individual liability under Title VII. ... As such, the Court agrees with the R & R of the Magistrate Judge that Plaintiffs claim against Defendant Shah, as an individual, should be dismissed.

Section 2000e’s employer definition does not permit Title VII claims against individuals in their individual capacities.

Churyumov v. Amazon Corporate LLC · filed 2019-11-25(b)

Such is the case here as Plaintiff’s Title VII and ADA claims against individuals are clearly precluded.

Section 2000e(b) does not treat individuals as employers who can be held personally liable under Title VII.

Barnwell v. Magellan Health Inc · filed 2019-12-03(b)

Under Title VII an individual is not considered an “employer” under the statute and individuals may not be liable in their individual capacities for violations of the statutes.

Section 2000e’s definition of employer does not make individual supervisors personally liable for Title VII violations.

Glover v. King · filed 2020-01-03(b)

Individuals such as King, even if they are an employee’s supervisor, may not be held personally liable for violations of Title VII.

Section 2000e(b) defines an employer for Title VII purposes; an individual supervisor is not liable as an employer.

Molchan v. Delmar Fire Department, Inc. · filed 2020-01-17(b)

As a threshold matter, the Court agrees with Defendants that Rementer must be dismissed from these claims because he is not an “employer” subject to liability within the meaning of Title VII or the DDEA.

Section 2000e(b) defines an employer for Title VII purposes; an individual manager who is not an employer cannot be sued in a personal capacity under Title VII.

Williamson v. United Parcel Service, Inc. · filed 2020-02-03(b)

Title VII and the ADA prohibit “employers” from discriminating on a variety of grounds but do not create a cause of action against persons who are not “employers.”

Section 2000e’s definition of employer excludes individual supervisors from personal liability under Title VII.

Perez v. Cook County Sheriff's Office · filed 2020-02-18(b)

Yet Title VII only provides a remedy against “employers” rather than individual supervisors. 42 U.S.C. § 2000e; 42 U.S.C. § 2000e-2.

Section 2000e(b) defines “employer”; an individual who is not the plaintiff’s employer cannot be sued in an individual capacity under Title VII.

Miller v. Upper Iowa University · filed 2020-02-21(b)

Bentley, Adams, Franken, and Duffy were not Plaintiffs’ employer, and therefore could not be sued in their individual capacities under Title VII.

Title VII permits employment discrimination claims against the employer as an entity, but not against individual employees outside the context of sole proprietors.

Haymon v. Metra · filed 2020-03-31(b)

As the Defendants correctly point out, Defs.’ Br. at 8, neither Title VII, the ADA, nor the ADEA permit individual-person liability (outside the context of sole proprietors).

Section 2000e(b) defines “employer” for Title VII; an individual who is not an employer cannot be added as a defendant to a Title VII claim.

Williamson v. United Parcel Service, Inc. · filed 2020-04-02(b)

Because Plaintiff does not allege that any of the four individuals is an “employer” or regulated entity for purposes of Title VII or the ADA, adding them as Defendants on either claim would be futile.

Section 2000e(b)’s definition of employer does not make a supervisor personally liable under Title VII solely because the supervisor is the employer’s agent.

Hubbard v. Evolution Wireless, Inc. · filed 2020-04-02(b)

Hubbard alleges that Watts was his supervisor and states no additional basis under which Watts would qualify as his “employer” within the definition of Title VII.

Section 2000e(b)'s definition of employer does not make supervisors individually liable for Title VII discrimination or retaliation claims.

Hodge v. Twin City Transportation · filed 2020-04-07(b)

The Eighth Circuit Court of Appeals has consistently held that supervisors may not be held individually liable under Title VII. ... Accordingly, the Court grants judgment in favor of defendants on Mr. Hodge’s Title VII discrimination and retaliation claims against Mr. Stewart in his individual capacity.

Section 2000e(b)’s definition of employer does not make a supervisor individually liable for Title VII violations unless the supervisor qualifies as an employer.

Hughley v. JetBlue Airways Corporation · filed 2020-06-24(b)

Moreover, the Complaint does not allege facts suggesting that Lopez is, in actuality, an employer within the meaning of § 2000e(b). Thus, Lopez is entitled to dismissal of the Complaint, because, as a supervisor, he cannot be held liable in his individual capacity for a Title VII violation.

Section 2000e(b)’s definition of employer excludes individual defendants who are not themselves employers from Title VII liability.

WILLIAMS v. NEW JERSEY TRANSIT RAIL OPERATION · filed 2020-06-29(b)

Because it is well settled that individual defendants who are not themselves employers are not liable under Title VII, the Court agrees.

Title VII does not impose individual liability on an employer’s administrators.

Asuncion v. Bard College · filed 2020-07-21(b)

But individuals may not be held liable under the federal employment anti-discrimination statutes, including Title VII.

Section 2000e(b) does not make a supervisor individually liable under Title VII unless the supervisor independently qualifies as an employer.

Bryant Bender v. General Dynamics Land Systems, Inc. · filed 2020-07-30(b)

Because DuQuet, who Plaintiff is suing as “a manager and agent” of General Dynamics, does not herself qualify as an “employer” under Title VII, Plaintiff’s discrimination claims against her must be dismissed.

Title VII’s definition of employer does not impose individual liability on a coworker for sexual harassment.

Fonseca-Bradford v. DuPage County Election Commission · filed 2020-08-03(b)

Stachniak moves to dismiss the claim against him in count one of Bradford’s complaint arguing that because he was an IT technician, he was not an “employer” for purposes of Title VII. Bradford has conceded in her response brief that Stachniak cannot be held individually liable under Title VII. The Court agrees, see Passananti v. Cook Cty., 689 F.3d 655, 677 (7th Cir. 2012) (citing Williams v. Banning, 72 F.3d 552, 555 (7th Cir. 1995). Thus, Stachniak, in his individual capacity, is dismissed from count I of the complaint.

Section 2000e(b)’s definition of employer does not make individual supervisory employees personally liable under Title VII.

Dunkley v. AFSCME · filed 2020-08-03(b)

“Employer” is defined as “a person engaged in an industry affecting commerce…and any agent of such a person[.]” 42 U.S.C. § 2000e(b). ... Such interpretations have generally been rejected, however, and both the Seventh Circuit and other circuits have generally come around to the principle that Title VII does not allow for liability on the part of individual supervisory employees. ... Accordingly, Dunkley’s Title VII claims against Peltes and Monroy must be dismissed.

Section 2000e(b) limits Title VII claims to employers; municipal officials cannot be sued in their individual capacities.

Reed v. City of Decatur, Alabama · filed 2020-08-20(b)

Accordingly, plaintiff’s Title VII claims against Mayor Bowling and Chief Allen in their individual capacities are due to be dismissed.

Section 2000e(b) defines an employer for Title VII purposes; individual supervisors cannot be held personally liable under Title VII.

DUKES v. NEW JERSEY TRANSIT · filed 2020-08-24(b)

Even assuming that Plaintiff exhausted his administrative remedies and timely filed his claims, no action may lie against Fraser in her individual capacity because Title VII does not recognize individual liability.

Section 2000e’s definition of employer does not make individual supervisors and coworkers liable under Title VII when they are not the plaintiff’s actual employer.

Pimentel v. Atrium Hospitality LP · filed 2020-09-08(b)

Pimentel is correct. “[I]ndividuals are not subject to liability under Title VII.”

Section 2000e(b) defines an employer for Title VII purposes; individual employees cannot be sued under Title VII solely for their own conduct.

Rawls-Dolin v. Riverside Regional Jail · filed 2020-09-25(b)

Title VII defines an 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, and any agent of such a person.” 42 U.S.C. § 2000e(b). ... Because Title VII does not provide a cause of action against individuals and Rawls-Dolin attempts to assert her Title VII claims against the individual defendants, the Court must grant the pending motions to dismiss on this ground.

Section 2000e(b)’s definition of employer does not make individual supervisors personally liable for Title VII discrimination.

Vasquez v. Steiner Enterprises Inc · filed 2020-10-01(b)

Holmes is an individual; he is the general manager of Mitchell Fabrics. Individual supervisors are not liable under Title VII or the ADEA for discriminatory conduct.

Section 2000e’s definition of employer does not make supervisors individually liable under Title VII when they are not the plaintiff’s employer.

Eddie L. Cooper v. Georgia Department of Transportation · filed 2020-11-17(b)

In addition, although Mr. Cooper purported to sue Mr. Avery and Mr. Cooper in both their individual and official capacities, they cannot be held liable under ADEA or Title VII in their individual capacities as they were not Mr. Cooper’s employer.

Section 2000e(b)’s definition of employer does not make individual supervisors personally liable for Title VII discrimination when they do not themselves qualify as employers.

Dale v. City of Paris · filed 2020-12-22(b)

Neither Sparkman nor Jordan qualify as employers under the statutes. Therefore, these individual defendants may not be held liable under either statute as a matter of law.

Section 2000e’s definition of employer does not make individual employees personally liable under Title VII.

Pitter v. Target Corporation · filed 2020-12-30(b)

Plaintiff's Title VII claims against the individual Defendants must be dismissed because "individuals are not subject to liability under Title VII."

Section 2000e(b) defines “employer” to include agents, but does not make employees individually liable under Title VII.

Bowie v. Hodge · filed 2021-01-06(b)

The court concludes that as to Bowie’s Title VII claims against Hodge, Martin, and Laughlin, she cannot state a claim. The Fifth Circuit has concluded that only the employer, and not the employees individually, can be held liable under Title VII. Thus, Bowie’s Title VII claims against Hodge, Martin, and Laughlin must be dismissed.

Title VII’s definition of employer does not make an ordinary supervisor individually liable for employment discrimination.

Colon-Gonzalez v. Commonwealth of Puerto Rico · filed 2021-02-05(b)

From the well-pleaded facts of the case, the Court understands that Defendant Garcia, as President of the CEE, holds duties and functions parallel those held by “an ordinary supervisor”, Lopez-Rosario, 245 F.Supp.3d at 371, and cannot, therefore, be individually liable under Title VII or the ADEA.

Section 2000e’s definition of employer does not make individual supervisors personally liable for Title VII discrimination or retaliation.

THEODORE v. NEWARK DEPARTMENT OF HEALTH AND COMMUNITY WELLNESS · filed 2021-02-10(b)

Title VII does not subject individual supervisory employees to liability.

Title VII does not permit claims against individual defendants; liability rests with employers.

Nouinou v. Guterres · filed 2021-03-30(b)

Moreover, as the Court has previously held, no claim under Title VII will lie against individual defendants.

Section 2000e’s definition of employer does not make supervisors individually liable under Title VII.

White v. Vance County, North Carolina · filed 2021-06-08(b)

A claim under Title VII may not proceed against an individual who does not qualify as an “employer.”

Section 2000e(b) defines the employer for a Title VII claim; supervisors are not personally liable.

Kongwa v. Enterprise Solutions, Inc. · filed 2021-07-19(b)

Moreover, as Title VII does not allow supervisors to be held personally liable, it would have been necessary to bring Gap in as a party to the EEOC proceedings.

Section 2000e(b)’s definition of employer does not permit Title VII claims against individuals who were not the plaintiff’s employer.

Coon v. UNC Rex Hospital · filed 2021-08-16(b)

Because Plaintiff does not allege that she was employed by any Defendant other than Rex, the claims against all other Defendants must be dismissed for failure to state a claim.

Section 2000e(b)’s definition of employer does not make a supervisor or owner individually liable under Title VII solely because of that role.

Knight v. Maaco Auto Body and Paint · filed 2021-09-16(b)

It is unclear from Mr. Knight’s complaint whether Mr. Lytle was Mr. Knight’s supervisor or whether he is an “owner” of the business, but, because Title VII applies solely to employers and not to either supervisors or owners, Mr. Lytle may not be held individually liable under Title VII.

Section 2000e(b)'s definition of employer excludes individual supervisors from personal liability under Title VII.

Hankle-Sample v. City of Chicago, The · filed 2021-09-29(b)

Defendants Billows, Consola, Flores, and Soni argue that Title VII does not impose individual or supervisor liability, and only an “employer” meeting the statutory definition can properly be sued. See 42 U.S.C. § 2000e(b) (defining “employer” as “a person engaged in an industry affecting commerce who has fifteen or more employees * * * and any agent of such a person.”); 29 U.S.C. § 630(b) (same). The Court agrees. None of the individual Defendants are employers, and Plaintiff raises no argument to the contrary.

Section 2000e’s employer definition excludes individual employees and supervisors who do not otherwise qualify as employers from personal liability under Title VII.

Curry v. Theaker · filed 2021-11-16(b)

An individual employee or supervisor, who does not otherwise qualify as an “employer” as defined by the statute cannot be held liable under Title VII.

Title VII’s definition of employer excludes a supervisor sued in an individual capacity, so the supervisor cannot be held individually liable under the statute.

LOVETT v. STEAK N' SHAKE · filed 2022-03-01(b)

Maddox, as an individual, does not fall within Title VII's definition of employer. Therefore, Maddox cannot be held individually liable and Lovett's Title VII claim against him is dismissed.

Section 2000e(b)’s definition of employer does not allow Title VII claims against individual defendants, including retaliation claims.

Mercado v. Mount Pleasant Cottage School Union Free School District · filed 2022-04-27(b)

Title VII does not provide for individual liability. ... Accordingly, the Court must dismiss Plaintiff’s Title VII claims against individual Defendants Beovich, Harris, and Weitmann with prejudice.

Section 2000e(b)’s definition of employer does not permit Title VII claims against employees or supervisors in their individual capacity.

Carter v. Baltimore City Police Department · filed 2022-05-17(b)

Neither Title VII nor related state law permits an employee or supervisor to be sued in their individual capacity.

Title VII’s definition of employer does not impose liability on a supervisor or coworker who is not the employer.

Julien v. St. John the Baptist Parish School System · filed 2022-07-07(b)

Here, Mr. Julien does not allege that Mr. Mayes or Mr. Brown were his employer, and the complaint explicitly names SJBPSS as his employer. (Rec. Doc. No. 1). The complaint further states that Mr. Mayes was an immediate supervisor and Mr. Brown was a co-worker. Id. Thus, any Title VII claims against Mr. Mayes or Mr. Brown are dismissed with prejudice in both their personal and official capacities.

Section 2000e(b) limits Title VII liability to employers, so supervisors and coworkers are not individually liable.

Avis v. Hillsboro R-3 School District · filed 2022-08-01(b)

Because Title VII does not impose individual liability on supervisors or coworkers, plaintiffs claims against Isaacson, Toeniskoetter, and Spiller must be dismissed.

Section 2000e(b)’s definition of employer does not make a supervisor individually liable merely because the supervisor acts as the employer’s agent.

Buksh v. Dr. William Sarchino DPM Foot and Ankle Surgeon · filed 2022-08-17(b)

In Meritor Savings, the Supreme Court acknowledged that an employer can be held liable for a supervisory employee that is considered an “agent” of the employer. Id. It does not, however, make the opposite point—that being an agent of the employer makes the agent individually liable. ... Therefore, the Court grants Dr. Sarchino’s motion to dismiss Plaintiffs’ First and Third Causes of Action.

Section 2000e(b) defines “employer”; individual school board members are not personally liable under Title VII.

RODEMAKER v. CITY OF VALDOSTA BOARD OF EDUCATION · filed 2022-08-31(b)

“The relief granted under Title VII is against the employer, not individual employees whose actions would constitute a violation of the Act.” ... The Court therefore GRANTS Defendants’ motion to dismiss Plaintiff’s Title VII claims against the individual Defendants.

Section 2000e(b) does not make a supervisor personally liable for a Title VII violation when the supervisor acts as the employer’s agent.

Perry v. Packerland Rent-A-Mat Inc · filed 2023-03-22(b)

Ott cannot be sued in his individual capacity for an alleged Title VII violation and therefore is not properly named as a party and Plaintiff has not stated a claim against him.

Section 2000e(b) does not make individual employees liable as employers under Title VII.

Misane v. Bangor, City of · filed 2023-04-10(b)

Accordingly, Simpson, Graham, and Williams are not “employers” under Title VII and are entitled to summary judgment on the Title VII claims against them.

Section 2000e’s definition of employer limits Title VII liability for individuals to those who qualify as employers.

Foster v. Asheville Buncombe Community Christian Ministry · filed 2023-04-24(b)

individuals are immune from suit under Title VII unless they qualify as an “employer” under the statute.

Section 2000e(b) defines who qualifies as a Title VII employer; an individual who does not qualify cannot be held liable under Title VII.

Lirette v. Sonic Drive-In Corporation · filed 2023-04-26(b)

Fifth Circuit precedent is clear that a plaintiff cannot state a claim against an individual under Title VII when that individual is not an “employer” as defined by §2000e(b).

Section 2000e(b) includes an employer’s agents in the definition of employer but does not make those agents individually liable under Title VII.

TEDROW v. FRANKLIN TOWNSHIP COMMUNITY SCHOOL CORPORATION · filed 2023-05-23(b)

Title VII and the ADA each define “employer” to include an employer’s agents. ... Ms. Britt and Principal Morris are correct that Title VII the ADA and GINA don’t impose liability on an employer’s agents and Mr. Tedrow agrees that they’re entitled to summary judgment.

Section 2000e(b)’s definition of employer does not make individual supervisors or coworkers liable under Title VII.

Avis v. Festus R-VI School District · filed 2023-06-05(b)

Title VII does not impose liability on individuals. ... Therefore, Plaintiff's Title VII claims against individuals are subject to dismissal.

Section 2000e(b) defines a Title VII employer to include a person engaged in an industry affecting commerce with at least fifteen employees; an individual supervisor who does not qualify as an employer is not personally liable.

Adkins v. Pilot Flying J · filed 2023-06-30(b)

With limited exceptions not applicable here, Title VIIdefines “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). ... The Amended Complaint does not include any facts that would permit the Court to conclude that any of these individuals qualifies as an “employer” under Title VII.

Section 2000e’s definition of employer excludes individual supervisors and co-workers from Title VII claims.

Smith v. UAMS · filed 2023-10-03(b)

Title VII only provides for claims against an employer company; Title VII does not provide for claims against individual supervisors or co-workers within the company.

Section 2000e(b)’s definition of “employer” excludes individual employees and supervisors from personal liability under Title VII.

Taylor v. AAON, Inc. · filed 2023-10-17(b)

Individual employees or supervisors do not qualify as “employers” under the statutory definition and are not subject to suit under Title VII or the ADEA.

Section 2000e’s definition of employer excludes individuals sued in their individual capacity under Title VII.

GREEN v. VAN AUSDALL AND FARRAR · filed 2023-11-02(b)

Title VII applies only to "employers"; it is well established that Title VII claims cannot be brought against individuals in their individual capacity.

Section 2000e defines an employer for Title VII purposes, and individual supervisors cannot be held personally liable as employers.

SCOTT v. ANTIC · filed 2023-12-05(b)

Title VII applies only to "employers"; it is well established that Title VII claims cannot be brought against defendants in their individual capacity. ... Therefore, to the extent that Ms. Scott intends to assert Title VII claims against Ms. Antic, Ms. Pressel, Ms. Peterson, and Mr. Mason, those claims are DISMISSED.

Section 2000e(b)’s reference to an employer’s agents makes employers liable for their agents’ acts; it does not make the agents individually liable under Title VII.

Kalkey v. Euromodas, Inc. · filed 2023-12-11(b)

Pertinently, Title VII imposes obligations on the employer, which it defines as a person “engaged in an industry affecting commerce” who, as mentioned earlier, has 15 or more employees during the period used to determine statutory coverage, and any agent of such a person. 42 U.S.C. § 2000e(b). ... Hence, the statute does not provide for individual liability.

Section 2000e’s definition of employer does not permit Title VII claims against employees or supervisors in their individual capacities.

DENHAM v. AMCOR FLEXIBLE NORTH AMERICA · filed 2024-01-08(b)

The statute applies only to "employers"; it is well established that Title VII claims cannot be brought against individuals in their individual capacity. ... Therefore, to the extent that Mr. Denham intends to assert Title VII claims against Mr. Godare, Mr. Rider, Mr. Frye, Mr. Griffey, Chrissy the Nurse, and Mr. Mitchell, those claims are DISMISSED.

Section 2000e(d) includes agents in its definition of a labor organization, but does not make individual union members or officers personally liable under Title VII.

Gaston v. American Association of University Professors · filed 2024-01-16(d)

In turn, Title VII defines a “labor organization” as “a labor organization engaged in an industry affecting commerce, and any agent of such an organization.” 42 U.S.C. § 2000e(d). ... Plaintiffs have provided no reason to depart from that presumption here, so the Court finds that use of “agent” in the definition of “labor organization” does not create liability against individual union members or officers.

Section 2000e(b) defines an employer; coworkers and supervisors who are not the plaintiff’s employer cannot be held individually liable under Title VII.

Wallace v. B.B. Rayburn Correctional Center · filed 2024-01-30(b)

Plaintiff’s Amended Complaint fails to allege that any of these individuals are her employer. ... Under binding Fifth Circuit precedent, those claims against the individual defendants must be dismissed with prejudice as they are not legally cognizable under Title VII.

Section 2000e’s definition of employer does not make an individual director personally liable under Title VII.

Petrus v. Silver Cross Hospital and Medical Centers · filed 2024-02-14(b)

Pryor thus cannot be individually liable under the ADA or Title VII as Plaintiff alleges.

Title VII’s definition of employer excludes individual employees from liability.

VALENTIN v. COMMONWEALTH OF PA. · filed 2024-02-21(b)

The United States Court of Appeals for the Third Circuit has declined to extend lability under Tithe VII to individuals, such as the Deputy Chief Counsel, and has held that the term “employer” as used in Title VII does not encompass individual employees.

An individual supervisor who is not the plaintiff’s employer is not personally liable under Title VII.

Morgan v. Bray · filed 2024-02-26(b)

Defendant Bray was not an employer subject to liability under the statute.

Section 2000e’s definition of employer generally does not make individuals personally liable under Title VII.

Andreasik v. Hunt, Gather, LLC · filed 2024-03-15(b)

In any case, Defendants are correct that Title VII and the IHRA generally do not support individual liability.

Section 2000e(b)’s definition of employer does not make an employer’s individual agents personally liable under Title VII when the employer is named as a defendant.

Allen v. McClendon · filed 2024-03-29(b)

Under Title VII, “[t]he term ‘employer’ means 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). ... Accordingly, to the extent that Mr. Allen has raised in his complaint Title VII claims against the individual Defendants instead of his employer, the Court dismisses without prejudice Mr. Allen’s Title VII claims against the individual Defendants.

Section 2000e(b)’s definition of employer does not make a supervisor personally liable under Title VII merely because he acts as the employer’s agent.

Norman v. RK Holdings, LLP · filed 2024-03-29(b)

Here, even when the law could consider Mr. Amrine to be Rural King’s “agent,” he still cannot be personally liable under Title VII.

Section 2000e(b)’s definition of employer does not make an individual manager or employee personally liable under Title VII solely because of that role.

Lundberg v. Delta Response Team, LLC · filed 2024-04-18(b)

Walton, as a “member, manager or director, officer, and employee of [Delta Response]” does not qualify as an “employer” under either the VHRA or Title VII.

Section 2000e’s definition of employer excludes supervisors from individual liability under Title VII.

Henderson v. Tower Federal Credit Union · filed 2024-04-22(b)

It is well-established that “supervisors are not liable in their individual capacities for Title VII violations.” ... Therefore, the only proper Defendant in this case is Plaintiff’s employer, TFCU.

Section 2000e(b) includes an employer’s agents in the definition of employer but does not make employees individually liable under Title VII.

Glover v. Lafayette Consolidated Government · filed 2024-07-22(b)

While Title VII defines the term employer to include “any agent” of an employer, 42 U.S.C. § 2000e(b), the Fifth Circuit does not interpret the statute as imposing individual liability for such a claim.

Section 2000e(b) limits Title VII discrimination claims to employers, so an employee who is not an employer cannot be sued for discrimination under Title VII.

Flores v. College of DuPage · filed 2024-08-13(b)

As an initial matter, Title VII and IHRA discrimination claims apply only to employers. See Williams v. Banning, 72 F.3d 552, 554 (7th Cir. 1995); see also 42 U.S.C. § 2000e(b); 775 ILCS 5/2-101, 5/2-102. Flores does not dispute that Martner is not an employer under Title VII and that he cannot state a claim against Martner for IHRA discrimination.

Section 2000e(b)'s definition of employer does not make individual employees personally liable under Title VII.

HALL v. CITY OF PHILADELPHIA · filed 2024-08-26(b)

Individuals may not be held liable under Title VII. ... The ADEA defines an employer in the same manner as does Title VII. Compare 29 U.S.C. § 630(b) with 42 U.S.C. § 2000e(b).

Section 2000e(b) defines an employer for Title VII; employees who are not themselves the employer cannot be held individually liable under Title VII.

Garrison v. Minnesota Department of Revenue of the State of Minnesota · filed 2024-09-19(b)

However, employment discrimination claims under both Title VII and the ADA may only be brought against employers, not against individuals who also work for that employer.

Section 2000e(b) defines a Title VII employer; former supervisors and coworkers cannot be held individually liable as employers.

Godfrey v. First Student · filed 2024-09-23(b)

In short, Title VII does not provide a basis for a cause of action against a non-employer.

Section 2000e’s definition of “employer” does not make individual managers liable under Title VII unless they themselves qualify as employers.

Tow v. Harris · filed 2024-11-15(b)

Accordingly, Plaintiff’s Title VII claims against Defendants fail as a matter of law because there is no basis for individual liability.

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

Tatum v. Gardner · filed 2025-01-24(b)

While Title VII defines “employer” to include any agent of the employer, see id. § 2000e(b), the Fifth Circuit does not interpret the statute to impose individual liability on the agent.

Section 2000e(b) defines who qualifies as an employer under Title VII; supervisors cannot be sued in their individual capacities for Title VII violations.

SMITH v. COLUMBUS TECHNICAL COLLEGE · filed 2025-01-30(b)

Title VII makes it unlawful for an “employer” to discriminate against any individual in the terms and conditions of employment because of her race or sex. 42 U.S.C. § 2000e-2(a)(1); see also 42 U.S.C. § 2000e(b) (defining “employer” as a person or entity who has fifteen or more employees). “The relief granted under Title VII is against the employer, not individual employees whose actions would constitute a violation of the Act.” Busby v. City of Orlando, 931 F.2d 764, 772 (11th Cir. 1991). Accordingly, individual capacity Title VII suits against supervisory employees are “inappropriate.” Id. The Court thus dismisses Smith’s Title VII claims against Wilkes and Burgan in their individual capacities.

Section 2000e(b) includes an employer’s agents in the definition of employer, but does not make them individually liable under Title VII.

Glenn v. Copeland's of New Orleans, LLC · filed 2025-02-19(b)

Although Title VII’s statutory definition of employer includes “any agent” of an employer, the Fifth Circuit does not interpret that language as imposing individual liability on agents.

Section 2000e(b)’s definition of “employer” excludes individual employees from personal liability under Title VII.

Davis v. Pete's Fresh Market 4700 Corporation · filed 2025-03-03(b)

The Court agrees that employees cannot be held individually liable for Title VII and ADEA violations because individuals do not meet the statute’s definition of “employer.”

Section 2000e(b) requires an individual to independently meet Title VII’s definition of an employer before facing individual liability for employment discrimination.

Smith v. Kompassionate Care LLC · filed 2025-03-12(b)

Instead, the individual must independently meet the definition of an “employer” under Title VII before individual liability for employment discrimination can be imposed. Id. Smith has not alleged facts sufficient to support suit against that Kompassionate employees Babalola or Gail in their individual capacity.

Title VII permits a discrimination claim against an employer, but not against the employer's individual employees or owner.

Orendorff v. STKJR III LLC · filed 2025-03-21(b)

To start, Orendorff cannot proceed on his claims against the individual defendants because Title VII only allows individuals to bring suits against their employer, not its employees or owner.

Title VII’s definition of employer does not make individual employees personally liable for workplace discrimination; the employing entity is the proper defendant.

DOUGLAS v. WESOLOWSKI · filed 2025-05-06(b)

Title VII and the ADEA do not authorize suit against individual employees alleged to have engaged in discriminatory conduct in the course of their employment.

Section 2000e’s definition of “employer” includes agents to make employers liable for their agents’ conduct, but does not make individual employees liable under Title VII.

Holmes v. Southeast Louisiana Flood Protection Authority East · filed 2025-04-29(b)

Although Title VII defines the term “employer” to include “any agent” of an employer, “Congress’ purpose was merely to incorporate respondeat superior liability into Title VII.” Smith v. Amedisys Inc., 298 F.3d 434, 448–49 (5th Cir. 2002).

Section 2000e(b)’s definition of employer does not make supervisors or co-workers individually liable under Title VII when they are not themselves employers.

Little v. Holzapfel · filed 2025-05-22(b)

But despite his arguments, Ms. Holzapfel and Ms. Morante are not employers under either Title VII or the ADA, and thus they cannot be held individually liable for the alleged discrimination.

Section 2000e(b)'s definition of employer excludes supervisors sued in their individual capacities, so they cannot be held individually liable under Title VII.

KINDER v. MARION COUNTY PROSECUTER'S OFFICE · filed 2025-06-02(b)

Thus, supervisors, like Scott, cannot be held individually liable under Title VII as the role falls outside the statute's definition of "employer."

A supervisor is not personally liable under Title VII unless the supervisor independently qualifies as an employer.

Rodriguez v. City of Galion, Ohio · filed 2025-06-24(b)

“It is well settled in the Sixth Circuit that ‘a supervisor who does not otherwise qualify as an employer cannot be held personally or individually liable under Title VII.’” ... Accordingly, Defendant Mayor O’Leary is entitled to summary judgment as to any claim of “imdividual liability” as a matter of law under Title VII, to the extent that such a claim could be said to have been included in the Complaint.

Section 2000e(b) defines employers covered by Title VII and excludes individual employees from personal liability.

Lanier v. Smedberg · filed 2025-07-29(b)

Liability under the ADA, the ADEA, and Title VII extends solely to “covered entities,” i.e., “employers” as specifically defined by statute, and those statutory definitions do not include individual employees.

Section 2000e(b) defines “employer” for Title VII; individual employees are not employers subject to liability under that definition.

ALLEN-MURPHY v. CITY OF PHILADELPHIA · filed 2025-09-25(b)

An “employer,” according to the provisions of Title VII, is defined 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). Courts have declined to extend liability under Title VII to individuals, holding the term “employer” as used in those statutes does not encompass individual employees. Sheridan v. E.I. DuPont de Nemours & Co., 100 F.3d 1061, 1078 (3d Cir.1996). Accordingly, the Title VII claims against McGrody, Craighead, Testa, Shrunk, Blango, Tucker, Hines, and Mulvey must be dismissed.

Section 2000e limits Title VII liability to employers and does not make individuals personally liable.

Rudolph · filed 2025-11-07(b)

Defendants correctly argue, however, that an individual defendant is not liable under Title VII.

Section 2000e’s definition of employer excludes a plaintiff’s supervisors, managers, and coworkers from individual Title VII liability.

Sears · filed 2025-11-14

The Court further notes that “Title VII does not allow for liability on the part of any person or entity other than Plaintiff’s ‘employer.’ And according to [the Sixth Circuit], under 42 U.S.C. § 2000e, an ‘employer’ does not include the ‘supervisors,’ ‘managers,’ or ‘co-workers’ of a plaintiff.” Han v. Univ. of Dayton, 541 F. App’x 622, 629 (6th Cir. 2013). Sears’ Title VII claims against her former hiring manager thus fail as a matter of law and are dismissable on this independent basis.

Section 2000e’s definition of employer does not include a plaintiff’s supervisors or managers, so they cannot be held individually liable under Title VII.

Bell v. Dollar Tree · filed 2025-11-21(b)

Thus, Bell’s Title VII claims against Kotsch, Jackson, Liddell, and Long fail as a matter of law and are dismissed.

Individual supervisors do not qualify as employers under Title VII and cannot be sued in their individual capacities.

Williams v. North Carolina Department of Public Safety · filed 2026-01-12(b)

Individual defendants do not qualify as “employers” for the purpose of Title VII.

Section 2000e(b) limits Title VII employer liability to employers; individuals are not liable in their individual capacities.

Jones · filed 2026-01-20(b)

As such, claims against individual defendants are subject to dismissal. See Smith v. St. Bernards Regional Medical Center, 19 F.3d 1254, 1255 (8th Cir. 1994) (concluding “that the claims against the individual defendants were properly dismissed because liability under 42 U.S.C. § 2000e(b) can attach only to employers”).

Section 2000e(b)’s definition of employer does not impose individual liability on an employer’s agents under Title VII.

Tatum v. Gardner · filed 2026-02-12(b)

That conclusion is correct under our precedent. See Indest v. Freeman Decorating, Inc., 164 F.3d 258, 262 (5th Cir. 1999) (“While Title VII defines the term employer to include ‘any agent’ of an employer, this circuit does not interpret the statute as imposing individual liability for such a claim.” (quoting 42 U.S.C. § 2000e(b)).