42 U.S.C. § 2000e

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

Brown · filed 2026-02-19(b)

Individuals simply 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.

Carey · filed 2026-02-19(b)

Having considered the parties’ memoranda, the record, and the applicable law, the Court grants the motion because the Defendants are individuals, and individuals cannot face liability under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e to 2000e-17 (“Title VII”).

Section 2000e(b) defines “employer” for Title VII; an individual employee who is not the plaintiff’s employer is not liable as an employer.

REILLY · filed 2026-03-09(b)

An “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). The United States Court of Appeals for the Third Circuit has declined to extend liability under Title VII to individuals, such as West, holding the term “employer” as used in Title VII does not encompass individual employees. Sheridan v. E.I. DuPont de Nemours & Co., 100 F.3d 1061, 1078 (3d Cir.1996). Since Reilly does not allege that West was her employer, the claim against him is not plausible for this additional reason.

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

Rehberger · filed 2026-04-06(b)

Although the definition of employer mentions an employer’s agents, the Seventh Circuit has held that Congress did not intend to impose individual liability on an employer’s agents. ... Therefore, Counts I and II must be dismissed as to Rehberger, Sr., Rehberger, Jr., Letizia Lowe, and Cody Lowe.

Section 2000e(b) treats a supervisor acting as an employer’s agent as a surrogate for the employer, without imposing individual liability under Title VII.

Pommier v. James L. Edelstein Enterprises · filed 1993-05-20(b)

In so doing, we held that neither Title VII nor the Equal Pay Act permits suit against corporate supervisors or management level officers in their individual capacities.

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

McElroy v. TNS Mills, Inc. · filed 1996-08-28(b)

Thus, the significance of Busby is that “even though Congress defined ‘employer’ to include ‘any agent,’ 42 U.S.C.A. § 2000e(b), this provision does not impose individual liability but only holds the employer accountable for the acts of its individual agents.”

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

Watts v. Kroger Co. · filed 1997-02-03(b)

The defendants submit that the plaintiffs Title VII claims against defendant Bullington must be dismissed because he is not an “employer” as defined by 42 U.S.C. 2000e(b). The plaintiff does not dispute this contention and confesses her Title VII claims as against defendant Bullington individually. Plaintiffs Mem. in Opp. to Summary Judgment Motion at 8-9. As such, the court shall dismiss the plaintiffs claims arising under Title VII as against defendant Bullington.

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

Moore v. State of Ala. · filed 1997-08-25(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). ... Therefore, plaintiffs’ Title VII claims against Jones in his individual capacity are due to be dismissed.

Section 2000e(b) does not permit Title VII claims against employees in their individual capacities.

Moore v. Alabama State University · filed 1997-09-26(b)

Plaintiff may not bring a claim against Steptoe under Title VII in his individual capacity.

Section 2000e(b) includes agents in its definition of employer but does not impose personal Title VII liability on supervisors.

Means v. Shyam Corp., et al. · filed 1997-11-12(b)

Title VII applies only to "employers" but defines the term to include "any agent of such a person", 42 U.S.C. § 2000e(b) (West 1994). ... in this district Title VII has been uniformly construed not to impose personal liability upon supervisors.

Section 2000e(b) does not make a corporate officer personally liable as an employer solely because he conducted business while the corporation was dissolved, when its reinstatement extinguished that liability.

Gardner v. 4 U Technology, Inc. · filed 2000-03-16(b)

The issue here is whether defendant Kuo may be liable to plaintiff as an "employer" under Title VII because he was an officer and director during the time the actions were taken, while the Corporation was administratively dissolved. ... As a result, Kuo may not be held personally liable to plaintiff under Title VII, the MHRA, the service letter statute or the sales commission statute, because liability on these claims is predicated solely on Kuo's status as the sole officer, director and shareholder of the Corporation during the time it was administratively dissolved.

Title VII’s definition of employer does not make an employer’s agents personally liable.

Scott v. Maryland State Department of Labor, Licensing & Regulation · filed 2016-12-20(b)

Nevertheless, regardless of whether the individual defendants were properly served, the district court correctly concluded that the violations of Title VII and the ADEA alleged in the complaint failed to state a claim for relief against them. ... Likewise, in Lissau v. Southern Food Services, Inc., interpreting similar language in Title VII, we held that individuals are not subject to liability under that statute.

A temporary staffing agency is an employer of a placed worker under Title VII only if common law agency principles establish an employment relationship; issuing the worker’s paycheck alone is insufficient.

Williams v. Caruso · filed 1997-06-06(b)

This fact, alone, is not sufficient to support a finding Williams was the employee of Western under agency principles. Therefore Williams may not sue Western for alleged “unlawful employer practices.”

Section 2000e(b) defines an employer to include a person engaged in an industry affecting commerce with at least fifteen employees; a staffing agency and a worksite company may each qualify when they exercise sufficient control over a worker.

Williams v. Grimes Aerospace Co. · filed 1997-12-19(b)

Grimes and Columbia Staffing clearly fit within Title VU’s definition for an “employer.” See 42 U.S.C.A. § 2000e(b) (“employer” is person engaged in industry affecting commerce with at least fifteen employees). Thus, to be Williams’ employer, each company must have exhibited the requisite control.

For employer status under § 2000e(b), the court adopted the Carparts test and Rivera-Vega factors over two narrower tests.

Bloom v. Crook · filed 1999-12-10(b)

Finding the Curran and the Heame test too narrow, the Court adopts the Carparts test, using the RivercAVega factors, as the clearest expression of the law in this circuit regarding employer status under Title VII.

Section 2000e(f)'s employment relationship requirement can cover a temporary worker and a staffing agency's client when the client sufficiently controls the worker's daily work.

Freeman v. Kansas · filed 2001-01-29(f)

Under the totality of the circumstances, the court finds the State was plaintiffs employer for purposes of Title VII. Although plaintiff was a temporary employee of Key Staffing assigned to work at the State, the State exerted sufficient control by supervising plaintiffs daily activities and providing the place of work and the tools to work to conclude that the State was plaintiffs employer.

Under Title VII, paying a worker does not make an entity the worker’s employer when another entity alone supervises the work and controls the essential terms and conditions of employment.

Sizova v. National Institute of Standards & Technology · filed 2002-03-13(b)

Contrary to Ms. Sizova’s argument, the fact that the fellowship program was a collaborative effort benefiting both NIST and the University does not mandate the inference that both entities therefore controlled her work given the undisputed evidence the NIST had sole control over the essential terms and conditions of her employment. In sum, we agree with the district court that the University was not Ms. Sizova’s employer for purposes of Title VII liability, and the district court therefore properly granted summary judgment for the University.

Evidence that a defendant controls workers’ daily work functions can create a factual dispute about its employer status under § 2000e(b).

Edwards v. Galveston-Texas City Pilots & Galtex Pilots Service Corp. · filed 2002-05-08(b)

The Court agrees with Plaintiff that a fact issue exists regarding Defendants' employer status under Title VII. Although Defendants claim that the Pilots are merely a group of independent contractors and that Galtex is merely a service corporation for the Pilots, Plaintiff produces at least some evidence showing that Defendants control the deputy pilots' daily work functions, which is the most crucial factor in assessing the existence of an employment relationship.

A company receiving a temporary worker is an employer under Title VII only if it controls the means and manner of the worker’s work.

Allen v. Tyco Electronics Corp. · filed 2003-12-02(b)

Under the loaned-servant doctrine, an employment relationship is created between the special employer and the temporary employee only when the special employer controls the means and manner of the temporary employee’s work. ... Therefore, as a matter of law, Tyco was not an “employer” of Ms. Allen within the meaning of Title VII.

Section 2000e(b) defines an employer under Title VII; a complaint that does not allege the defendant is an employer cannot support a Title VII claim against it.

Martinez v. City of St. Louis · filed 2004-01-30(b)

[2] Specifically: (1) plaintiffs' complaints do not allege that F.I.R.E. is an "employer" within the meanings of either Title VII of the United States Code, see 42 U.S.C. § 2000e(b), or the Missouri Human Rights Act, see Mo. Stat. § 213.010(7); (2) plaintiffs' complaints do not allege that F.I.R.E. intentionally discriminated against them in violation of 42 U.S.C. § 1981; and (3) plaintiffs' complaints do not allege that F.I.R.E. acted under color of state law or that F.I.R.E. acted in violation of 42 U.S.C. § 1983.

Section 2000e(b) can cover an entity that exercises sufficient control over a worker’s employment, even when another entity directly hires the worker.

El v. Southeastern Pennsylvania Transportation Authority · filed 2005-07-12(b)

In light of this evidence, we find that issues of material fact exist as to whether SEPTA exercised sufficient control over the plaintiffs employment with King Paratransit Services to render it an employer within the meaning of Title VII.

Employer status under Title VII turns chiefly on the alleged employer’s right to control the means and manner of the worker’s performance.

Amiri v. Stoladi Property Group · filed 2005-10-04(b)

The extent of the alleged employer’s right to control the “means and manner” of the worker’s performance is the most important factor in determining whether an employer/employee relationship exists for Title VII purposes. ... It is clear that Stoladi was not plaintiffs employer for the purposes of Title VII liability.

A Title VII claim requires the plaintiff to allege that the defendant was his employer.

Heller v. Consolidated Rail Corp. · filed 2009-05-26(b)

Additionally, as appellant did not allege that either the EEOC or the Railroad Retirement Board was his employer, he could not state a claim against them under the provisions of Title VII, the Americans with Disabilities Act, and the ADEA, which apply only to discriminatory practices by an employer.

A franchisor may be an employer of a franchisee’s worker under Title VII when the two satisfy the single employer test, which focuses on control over employment decisions.

McLaurin v. Fusco · filed 2009-06-01(b)

Thus, the Trevino analysis applies to determine whether Jenny Craig was also her employer; yet there is neither allegation nor sufficient proof to support finding Jenny Craig to be her employer under Trevino’s “single employer” test.

Section 2000e’s employer definition can cover an entity that controls some aspects of a worker’s terms and conditions of employment.

Lima v. Addeco · filed 2009-06-09(b)

These documents certainly indicate that Adecco controlled at least some aspects of Lima’s terms and conditions of employment, such that a fact question exists as to Adecco’s employer status.

Section 2000e’s employer definition requires a plaintiff to show that the defendant was her employer to maintain a Title VII claim against it.

KUDATZKY v. Minskoff · filed 2010-04-22

Having reviewed the complaint, 590 Madison’s motion to dismiss the complaint, and other papers on file in this action, and upon application of governing law and standards pertaining to Rule 12 motions and Title VII claims, the Court finds that Kudatzky has failed to sufficiently demonstrate that 590 Madison was her employer during the events at issue in this action, and thus her Title VII claims against 590 Madison must fail.

Section 2000e(b) limits Title VII employer liability to an entity that employs the plaintiffs, including one that qualifies as a joint or single employer.

Hollinghead v. City of York · filed 2014-03-31(b)

The plaintiffs were employed by the City of York, but they were not employed by the Authority, •and thus the plaintiffs’ claims for unlawful workplace against the Authority under Title VII and the PHRA fail as a matter of law.

Employer status under Title VII depends on control over the worker’s pay, hiring, firing, and daily activities.

Bourne v. V.C. Enterprise/Kirby Home Cleaning System · filed 2016-01-20(b)

At issue is whether The Kirby Company was Bourne’s employer within the meaning of Title VII. ... In light of the forgoing, the court concludes that no reasonable jury could find that The Kirby Company was Bourne’s employer or that it discriminated against Bourne in violation of Title VII.

An agent qualifies as a Title VII employer only if it has authority over employment practices; authority to approve or deny benefit claims does not suffice.

Baker v. Aetna Life Insurance Co. · filed 2017-01-13(b)

And this circuit recognizes an agency theory of employer liability only if the alleged agent had authority “with respect to employment practices.”

Section 2000e covers an employment relationship when the defendant controls the worker’s assignments, schedule, supervision, and other terms of employment.

Toomer v. Federal Reserve Bank St. Louis · filed 2021-09-15

Construing these allegations as true, Plaintiff’s Complaint sufficiently alleges FRB STL was her employer for Title VII purposes.

A Title VII claim against an alleged employer requires facts plausibly showing an employment relationship; a conclusory assertion that the entity employed the plaintiff is insufficient.

Harris v. State of New York · filed 2022-02-14(b)

However, Title VII’s definitions of employer and employee are not “particularly helpful in deciding whether an employment relationship exists.” ... Therefore, Plaintiff fails to allege that the State is his employer, and accordingly, his Title VII claim against the State is dismissed without prejudice.

A complaint must plausibly allege that a defendant entity was the worker’s employer to state a Title VII claim against it.

Budzyn v. KFC · filed 2022-03-30(b)

Accordingly, Budzyn has not sufficiently alleged that KFC Corporation was her employer for Title VII purposes under the federal pleading standards.

Whether a defendant qualifies as a Title VII employer is an element of the claim, not a jurisdictional question.

Uzzolino v. Corriveau · filed 2023-01-18(b)

Further, a Defendant’s qualification as the “employer” of a Title VII plaintiff constitutes a “substantive ‘element of [the] plaintiff’s claim for relief, not a jurisdictional issue.’” ... State Farm’s motion to dismiss the complaint pursuant to Rule 12(b)(1) is denied.

An entity qualifies as a Title VII employer, alone or jointly with another entity, only if it exercises sufficient control over the worker’s employment.

Garcia v. The Arker Companies, LLC · filed 2024-08-21(b)

Having failed to advance evidence weighing in her favor on any of these factors, plaintiff cannot succeed in showing that either The Arker Companies or Chateau exercised the degree of control over the terms and conditions of her employment sufficient to deem them her “employer,” whether solely or jointly.

An entity is not an employer under Title VII’s single-employer test when it lacks meaningful control over the employee’s labor relations, even if it provides payroll and administrative support.

Trujillo v. Rio Grande County Sheriff's Office · filed 2025-09-29(b)

Because Plaintiff has failed to establish an employment relationship between herself and the County, her Title VII and ADA claims against the County fail.

A parent company may be liable as an employer under Title VII when it and its subsidiary form a single, integrated enterprise, but a conclusory allegation does not establish that relationship.

Tilford · filed 2025-12-09(b)

The court concludes that the allegations of Tilford’s complaint are insufficient to plausibly plead that TEGNA and WFAA are a single, integrated enterprise.

Section 2000e(b) defines who counts as an employer under Title VII.

Hines v. Olinkraft, Inc. · filed 1978-07-11(b)

Olinkraft is an employer within the meaning of 42 U.S.C. § 2000e(b).

Section 2000e(b) defines which entities are employers under Title VII.

Cobb v. Anheuser Busch, Inc. · filed 1990-10-24(b)

Defendant Anheuser-Busch, Inc. ("the Company") is a corporation existing under the laws of the State of Missouri and is an employer within the meaning of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, et seq.

Section 2000e(b) requires an employer to have at least fifteen employees; a genuine factual dispute over that threshold prevents summary judgment on a Title VII claim.

Cox v. Global Tool Supply LLC · filed 2022-09-20(b)

Plaintiff has likewise shown a genuine dispute of material fact as to whether Global Tool employed over fifteen employees, rendering summary judgment on Plaintiff’s Title VII claim inappropriate.

Section 2000e(b) requires a plaintiff to prove that the employer met Title VII’s fifteen-employee threshold.

Carlisle v. Rhodes & Rhodes Family Dentistry · filed 2022-06-02(b)

Even though Plaintiff has failed to demonstrate that Defendant employed fifteen or more employees at the time, the Court will analyze Plaintiff’s claims.

Section 2000e(b) requires a Title VII employer to have at least 15 employees for each working day in 20 or more weeks of the current or preceding year.

Stoutenger v. Fulton Community Development Agency · filed 2022-06-02(b)

The allegations in the FAC do not plausibly support an inference that FCDA employed at relevant times 15 or more employees sufficient to meet §2000e(b)’s threshold requirement.

Section 2000e(b) requires an employer to have at least fifteen employees for Title VII to apply.

Aponte v. Clinton Street Pizza Inc. · filed 2022-04-19(b)

Title VII applies to employers who have “fifteen or more employees.” See 42 U.S.C. § 2000e(b); Arbaugh v. Y & H Corp., 546 U.S. 500, 504 (2006) (stating that “the employee-numerosity requirement” relates to the “substantive adequacy” of a Title VII claim). The Complaint contains no facts regarding CSP’s number of employees and, consequently, fails to state a claim pursuant to Title VII.

Section 2000e(b) requires an employer to have at least fifteen employees; employees in offices in different countries count together when the offices belong to the same company.

Friederick v. Passfeed, Inc. · filed 2022-03-31(b)

To be subject to Title VII, a defendant must employ at least fifteen employees. 42 U.S.C. § 2000e(b) (defining “employer” to include only those having “fifteen or more employees”). ... The Court thus concludes that, once combined—even without considering the 49 individuals in the WhatsApp Passfeed Family message thread—Plaintiff has plausibly alleged that Passfeed employs the requisite minimum number of employees to be held liable under Title VII.

Section 2000e(b)’s employee-count requirement is a statutory element of a Title VII claim that an employer waives by raising it too late.

Tate v. Zaleski · filed 2022-02-17(b)

First, while a plaintiff ordinarily must establish the requisite number of employees as a statutory element of a Title VII claim, Defendants waived this issue by failing to raise it until the close of Plaintiffs’ case.

Section 2000e(b) defines a covered employer as one with at least fifteen employees for each working day in at least twenty calendar weeks of the current or preceding year.

Taylor v. Go-Getters, Inc. · filed 2021-12-09(b)

However, as noted, Title VII and MFEPA apply only to employers with “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); S.G. § 20-601(d). ... And, this list suggests that Go-Getters employs more than enough individuals to render it subject to Title VII’s and MFEPA’s provisions.

Section 2000e(b) requires at least fifteen employees for an entity to qualify as a Title VII employer.

Marski v. Courier Express One, Inc. · filed 2021-09-29(b)

Additionally, even if Plaintiff could satisfy the requisite tests with respect to Dispatch, Dispatch would not constitute an employer for the purpose of Plaintiff’s Title VII, ADA, ADEA, and FMLA claims, or Plaintiff’s IHRA claims to the extent based upon age or sex discrimination, because Dispatch employed only approximately ten people. ... This number falls short of the requirements for “employers” within the meaning of Title VII, the IHRA, the ADA, the ADEA, and the FMLA.

Section 2000e(b) requires an employer to have at least 15 employees for Title VII to apply.

BENDER v. AVON EDUCATION FOUNDATION · filed 2021-07-13(b)

For Title VII to apply, a company must have 15 or more employees. See 42 U.S.C. § 2000e(b).

Section 2000e(b) limits Title VII coverage to employers with at least fifteen employees, and a complaint must plead facts supporting that threshold.

Aponte v. Taormina · filed 2021-05-17(b)

Title VII applies to employers who have “fifteen or more employees.” ... The Complaint contains no facts regarding CSP’s number of employees and, consequently, fails to state a claim pursuant to Title VII.

Section 2000e(b) requires a covered employer to have at least fifteen employees for each working day in twenty or more calendar weeks of the current or preceding calendar year.

Yazzie v. National Organization for Women · filed 2021-03-30(b)

The Court, accordingly, concludes that a dispute of material fact remains in this case as to whether NOW “ha[d] fifteen or more employees for each working day in each of twenty or more calendar weeks in” years when Yazzie alleges the discrimination occurred.

Section 2000e(b) requires an employer to have at least fifteen employees during the specified twenty-week period.

Amber Springer v. First Call Pregnancy Center · filed 2020-12-08(b)

Title VII limits the definition of “employer” to entities that have “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). ... But there was no error in the district court’s finding or in its application of the law. ... The district court therefore properly granted summary judgment on the basis that First Call was not an employer under Title VII.

Section 2000e(b)’s fifteen-employee threshold is adequately pleaded by alleging that the employer had more than fifteen employees during the relevant period.

Richardson v. Buckheit · filed 2020-09-29(b)

The defendants are incorrect. Richardson adequately alleges that KCPA employed more than fifteen employees during the relevant period.

Section 2000e(b) requires at least fifteen employees for an entity to qualify as an employer under Title VII.

Bennett v. Beaufort County · filed 2020-04-17(b)

The Magistrate Judge further found that Beaufort County Council is not subject to suit under Title VII because it does not employ the requisite “fifteen or more employees.” ... The Court disagrees and finds no error in the Magistrate Judge’s conclusion that, by law, the County Council only appoints two employees: the Clerk to Council (Plaintiff’s former position) and the County Administrator.

Section 2000e(b) covers an employer only if it employed at least fifteen employees for at least twenty weeks in the current or preceding calendar year.

Garcia v. Marc Tetro, Inc. · filed 2020-03-02(b)

Defendants have provided timesheets that demonstrate that they did not employ fifteen or more employees for at least twenty weeks in 2016 or 2017. See Dkts. 32-1, 32-2, 32-3. Because there is no contrary evidence in the record, the Court concludes that there is no genuine dispute of material fact that Defendants are not “employers” within the meaning of Title VII.

Section 2000e(b) requires an employer to have at least fifteen employees for each working day in at least twenty weeks of the current or preceding year.

Doe v. The Grand Company, LLC · filed 2020-02-18(b)

Therefore Zaher Management and the other Zaher family LLCs, even if aggregated into a single entity, were not “employers” under Title VII.

Section 2000e(b) limits Title VII’s employment discrimination protections to employers with at least fifteen employees for the specified period.

ELSAYED v. FAMILY FARE LLC · filed 2020-02-18(b)

This ban on employment discrimination only applies to employers who have “fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” See Walters v. Metro. Educ. Enters., Inc., 519 U.S. 202, 204 (1997) (quoting 42 U.S.C. § 2000e(b)). ... Here, Plaintiff failed to plead that Defendants employ fifteen or more individuals. (See ECF Nos. 1; 21-1.) Therefore, the Court will deny Plaintiff’s motion to amend.

Section 2000e’s definition of employer includes state law enforcement employers.

United States v. Pennsylvania · filed 2015-05-21(b)

Congress was “[unquestionably” aware of the Griggs disparate “impact standard applicable to private employers when it amended Title VII in 1972 to include state and local government employers,” United States v. Virginia, 620 F.2d 1018, 1023 (1980), and it did so without exempting state law enforcement employers, see 42 U.S.C. § 2000e(a)-(b); Equal Employment Opportunity Act of 1972, Pub.L. No. 92-261, § 2 (1972).

Section 2000e(b) defines a Title VII employer as an entity with at least 15 employees for each working day in 20 or more calendar weeks in the current or preceding calendar year.

Vazquez v. Orange County Service Unit · filed 2015-03-26(b)

The District Court found that OSCU was not an employer because it did not employ fifteen or more employees during the relevant time period. Vazquez challenges this finding. We find no error. Viewed in the light most favorable to Vazquez, the evidence showed that OSCU never employed more than 14 employees during the relevant time period.

Section 2000e(b) requires an employer to have at least fifteen employees; employees of separate entities may be counted together when the entities are joint or single employers.

Avington v. Metropolitan Tulsa Urban League · filed 2015-02-11(b)

In some circumstances, courts may treat separate entities as a joint or single employer for purposes of determining the threshold number of employees required for an employer to be subject to suit under Title VII or the ADEA. ... The undisputed facts fail to show NUL exercising any control over MTUL’s employment decisions, employees or the terms and conditions of employment with MTUL, and no evidence of common management; common or centralized control of labor relations, or common ownership and financial control.

Section 2000e(b) requires an employer to have at least fifteen employees for twenty or more weeks in a year.

Clark v. St. Joseph/Candler · filed 2007-04-04(b)

The undisputed evidence establishes that MRC did not employ fifteen or more employees for twenty or more weeks in a given year.

Section 2000e(b)’s 15-employee threshold can include shareholder-directors of a close corporation; their employee status depends on the Clackamas control test, not their titles alone.

De Jesús v. LTT Card Services, Inc. · filed 2007-01-19(b)

We also hold that the Clackamas test applies to Title VII as well as ADA claims. ... The defendants must also meet their burden under the six-factor Clackamas test.

Section 2000e(b) requires an employer to have at least fifteen employees for each working day in twenty or more calendar weeks of the current or preceding year.

Leday v. Ville Platte Housing Authority · filed 2006-12-06(b)

Under 42 U.S.C. § 2000e(b) (emphasis added) an 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. . . .” (Emphasis added). It is clear that the VPHA had only eight to ten employees throughout the time in question. ... Without meeting the threshold requirement of showing that her employer employed fifteen people, Ms. Leday cannot pursue her Title VII claim.

Section 2000e(b) limits Title VII employer status to entities with at least fifteen employees for each working day in twenty or more calendar weeks of the current or preceding year.

Arculeo v. On-Site Sales & Marketing, LLC and Sanford Pankin, Also Known as Crystal Hills, Docket No. 04-3807 C · filed 2005-09-30(b)

Title VII imposes liability for employment discrimination only on an “employer,” which is defined by the statute 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).

Owners who do not qualify as employees cannot be counted toward § 2000e(b)’s fifteen-employee threshold.

Fitzgibbons v. Putnam Dental Associates, P.C. · filed 2005-05-11(b)

Dr. Ern, Betsy Ern, Andrew Ern and Dr. Vincent Cafarelli are not “employees” as the term is contemplated by Title VII; thus, Putnam Dental does not employ the required threshold number of fifteen employees necessary for the application of Title VII.

Section 2000e(b) covers employers with at least fifteen employees on each working day in twenty or more calendar weeks in the current or preceding year.

Stinnett v. Iron Works Gym/executive Health Spa, Incorporated · filed 2002-08-26(b)

The law allowing victims of sexual harassment to sue their employers applies only to those businesses with fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.

A Georgia school district can qualify as a covered employer under Title VII.

Walton v. Dougherty County School System · filed 1997-06-20(h)

The School System is a covered “employer” under Title VII. 42 U.S.C. § 2000e(h).

Section 2000e covers a state governmental unit that employs more than 15 people.

National Ass'n for Advancement of Colored People v. Town of East Haven · filed 1998-03-25(a) and (b)

As a state governmental unit employing more than 15 persons, East Haven is subject to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e(a) and (b).

Section 2000e(b) permits related companies to be treated as a covered employer when evidence supports an integrated enterprise or agency relationship.

Platt v. Kini L.C. · filed 1998-07-07(b)

Considering these factors, the Court cannot conclude as a matter of law that Liberty, doing business as Kansas Cellular, is not a covered employer under Title VII. ... On this record, the Court cannot conclude that a reasonable jury- would reject'a claim that the two entities are an integrated enterprise under Frank or that an agency relationship exists between them.

Section 2000e’s definition of employer includes the Texas Department of Transportation.

Pfullman v. Texas Department of Transportation · filed 1998-10-16(b)

TxDot is an “employer” within the meaning of the Civil Rights Act of 1964, 42 U.S.C. § 2000e.

Section 2000e(b) measures employer coverage using the year of the alleged discrimination or the preceding calendar year, including for a new employer.

Dodi KOMOROWSKI, Plaintiff-Appellant, v. TOWNLINE MINI-MART AND RESTAURANT, Defendant-Appellee · filed 1998-12-11(b)

Because Komorowski’s alleged retaliatory discharge occurred in 1996, the relevant years for determining Townline’s status as an “employer” under Title VII are 1996 and 1995. Townline did not exist in 1995, and it employed more than fifteen employees for only approximately seventeen weeks during 1996. Therefore, the district court properly concluded that Townline was not an “employer” as defined by § 2000e(b).

Section 2000e(b) generally covers employers with at least 15 employees and does not exclude national banks.

Peatros v. BANK OF AMERICA NT & SA · filed 2000-01-10(b)

The employer, among other things, must generally have 15 or more employees. (Civil Rights Act of 1964, § 701(b), as amended, 42 U.S.C. § 2000e(b).) All such employers are included with coverage—with the sole exception of the United States, any corporation wholly owned by the federal government, any Indian tribe, certain departments and agencies of the District of Columbia, and certain bona fide private membership clubs.

Section 2000e(b) counts union stewards as employees toward Title VII's fifteen-employee requirement when their compensation and working relationship establish employment by the union.

Daggitt v. United Food & Commercial Workers International Union, Local 304A · filed 2001-04-04(b)

In sum, we hold that the union stewards of UFCW are "employees" of the union for purposes of establishing jurisdiction over the union under 42 U.S.C. § 2000e(b).

Section 2000e(b)’s fifteen-employee threshold counts a person on each working day of an ongoing employment relationship, even when the person did not work or receive pay that day.

Latimer v. Wise · filed 2001-08-02(b)

However, under the payroll method test, E. Wise would be an “employee” that week, whether he or she actually worked or was compensated for working.

Section 2000e(b)’s fifteen-employee threshold excludes an employer with fewer than fifteen employees from Title VII liability.

Blagg v. Technology Group, Inc. · filed 2004-01-21(b)

Given that finding, I must conclude that I lack subject matter jurisdiction over Blagg’s Title YII claim in her first claim for relief because defendants did not employ fifteen employees and thus are not subject to Title VII liability.

Section 2000e(b)’s fifteen-employee threshold is a substantive element the plaintiff must prove, not a jurisdictional requirement.

Thomas v. Meister Heating & Air Conditioning, Inc. · filed 2004-03-05(b)

Whether Meister had fifteen employees is not a jurisdictional question. ... It is a substantive element Thomas must prove to establish her claim.

A plaintiff must provide evidence that the defendant met Title VII’s minimum employee count to qualify as an employer.

Burgett v. Utah Valley Veterinary Hospital · filed 2004-05-18(b)

Having reviewed the briefs, the record, and the applicable law, we determine that Ms. Burgett has not provided evidence demonstrating that UVVH had the minimum number of either paid or unpaid workers to qualify as a Title VII employer.

Section 2000e(b) does not permit separate joint employers to combine their employees to meet Title VII’s fifteen-employee minimum.

Arculeo v. On-Site Sales & Marketing, LLC · filed 2004-06-16(b)

Thus, having concluded that employees of joint employers may not be aggregated to meet the fifteen-employee minimum of Title VII, it is clear that plaintiffs relief in this case is to be had in state court under the NYHRL, which has a four-person minimum instead.

Section 2000e(b) requires an employer to have at least fifteen employees to be covered by Title VII.

Sanford v. Main Street Baptist Church Manor, Inc. · filed 2009-05-20(b)

As stated above, an employee must show that an employer has at least fifteen employees to meet the employee-numerosity requirement of Title VII, § 2000e(b), and at least eight employees to meet the employee-numerosity requirement of the Kentucky Act.

Section 2000e(b) requires an employer to have at least fifteen employees for each working day of twenty or more calendar weeks in the current or preceding year for a Title VII claim.

Rife v. Borough of Dauphin · filed 2009-07-17(b)

To state a claim under Title VII, Plaintiff must allege and prove that his employer had fifteen or more employees for each working day of twenty or more calendar weeks in the current or preceding year. ... In light of Plaintiff s concession that the Borough of Dauphin never employed more than 15 people, Plaintiff’s Title VII claim fails as a matter of law and the court will grant Defendants’ motion for summary judgment on these claims.

Section 2000e(b) requires an employer to have at least fifteen employees for each working day in twenty or more calendar weeks in the current or preceding year for Title VII to apply.

Feliciano v. 131st Block Ass’n Inc. · filed 2012-03-16(b)

However, as the district court properly concluded, the undisputed evidence (in the form of the employer’s payroll records) shows that Appellant’s employer never “ha[d] fifteen or more employees for each working day in each of twenty or more calendar weeks in” these years or in the “preceding calendar year,” as required for Title VII to apply to the employer’s conduct.

A plaintiff alleging that a corporate defendant employs more than fifteen people need not also plead that the defendant falls outside § 2000e(b)’s employer exclusions.

Wright v. Koniag Services, Inc. · filed 2012-04-10(b)

Since Wright’s complaint alleges KSI “is a Virginia Corporation that employs more than fifteen employees and has offices located in Baltimore County, Maryland” (Compl. ¶ 4), the complaint adequately alleges the necessary definition of “employer” for a Title VII claim. Surely, a plaintiff is not required to plead that the defendant is not an ANRC or any of the other entities listed in 42 U.S.C. § 2000e(b).

Section 2000e(b) covers an employer only if it has at least fifteen employees for each working day in twenty or more calendar weeks in the current or preceding calendar year.

Gonzalez v. Micelli Chocolate Mold Co. · filed 2013-03-14(b)

As the magistrate judge properly concluded, however, the undisputed evidence (in the form of Micelli’s payroll records) shows that Micelli never “ha[d] fifteen or more employees for each working day in each of twenty or more calendar weeks in” 2008 or in the “preceding calendar year,” as required for Title VII to apply to Micelli’s conduct. 42 U.S.C. § 2000e(b). As Micelli is not a covered employer under Title VII, Gonzalez’s claim fails as a matter of law.

Section 2000e(b)'s employee threshold determines whether an organization is an employer for Title VII purposes.

Aly v. Mohegan Council, Boy Scouts of America · filed 2013-03-22(b)

We find that, viewed in the light most favorable to the verdict, Mohegan Council met the threshold number of employees to constitute an "employer" for Title VII purposes.

Section 2000e(b) requires an employer to meet the fifteen-employee threshold; a genuine dispute over whether contracted doctors were employees prevented summary judgment on employer status.

Rodriguez-Vega v. Policlinica La Familia De Toa Alta, Inc. · filed 2013-04-29(b)

Without further evidence of how the doctors are treated for Social Security and the amount of control defendant Policlinica has over how the doctors carry out their work, a genuine dispute of material fact remains about whether the doctors constitute employees or independent contractors. If the doctors are employees pursuant to Title VII, then the Policlinica would have more than fifteen employees and would be considered an employer pursuant to Title VII. Thus, the Court DENIES defendant Polielinica’s request for summary judgment on the grounds that it is not an employer pursuant to Title VII.

Section 2000e(b)’s 15-employee requirement applies to public and private employers alike.

Ugorji v. New Jersey Environmental Infrastructure Trust · filed 2013-06-18(b)

As to the first argument, Title VII‘s 15-employee requirement does not distinguish between public and private employers.

Section 2000e(b) requires an employer to have fifteen or more employees for each working day in at least twenty calendar weeks of the current or preceding year.

Taylor v. Cardiology Clinic, Inc. · filed 2016-07-19(b)

In 2013, the only year brought into issue, Defendants did not have fifteen or more employees for each working day in each of twenty or more calendar weeks. For purposes of Plaintiffs action, Defendants are not a Title VII “employer.”

Section 2000e(b) covers employers with 15 or more employees, including government entities such as a parish sheriff’s office.

Bowie v. Hodge · filed 2020-08-17(b)

Employers with 15 or more employees, including government entities such as the Orleans Parish Sheriff’s Office, are governed by Title VII.

Section 2000e(b) sets a 15-employee threshold for employers covered by Title VII.

North Dakota, State of v. Burwell · filed 2021-01-19(b)

CBA members offer health plans with such exclusions and have more than 15 employees, bringing them squarely within Title VII’s reach.

Section 2000e(b) requires an employer to have at least fifteen employees for each workday in at least twenty calendar weeks of the current or preceding calendar year to be covered by Title VII.

Gergawy v. United States Bakery Inc d/b/a Franz Family Bakeries · filed 2021-03-09(b)

Covered employers under Title VII and the ADA must have had at least fifteen employees for each workday in at least twenty calendar weeks in the current or preceding calendar year. ... Accordingly, the Court grants the OHS Defendants’ motion on the basis that they are not covered employers under Title VII, the ADA, and the ADEA.

Section 2000e’s definition of employer covers the City of Omaha.

Belcastro-Gonzalez v. City of Omaha · filed 2022-08-17(b)

The City of Omaha qualifies as an “Employer” under 42 U.S.C. § 2000e.

Title VII covers employers with at least fifteen employees that are engaged in an industry affecting interstate commerce.

Aponte v. Clinton Street Pizza Inc. · filed 2023-02-07(b)

Title VII applies to any employer that has “fifteen or more employees” and is “engaged in an industry affecting [interstate] commerce.” ... Plaintiff Aponte alleges that Defendant CSP “had at least fifteen (15) employees” and engaged in interstate commerce during the period of her employment.

Section 2000e(b) gives Title VII broad employer coverage, reaching entities engaged in an industry affecting commerce with fifteen or more employees.

Dawn Polk v. Amtrak National Railroad Passenger Corporation · filed 2023-04-26(b)

And the broad reach of Title VII cautions against displacing other statutory procedures that are focused on a narrow problem. Title VII governs almost any entity country-wide “engaged in an industry affecting commerce” so long as it has fifteen or more employees. 42 U.S.C. § 2000e(b).

Section 2000e(b) does not itself make Title VII applicable to the U.S. Capitol Police; the Congressional Accountability Act extends Title VII protections to covered Capitol Police employees.

Tango v. United States Capitol Police · filed 2023-06-26(b)

While Title VII does not on its face apply to USCP, see 42 U.S.C. § 2000e(b), the Congressional Accountability Act (“CAA”), 2 U.S.C. § 1301 et seq., “extends the protections of Title VII . . . to covered employees of the federal legislative branch, including the Capitol Police.” Breiterman v. U.S. Capitol Police, 15 F.4th 1166, 1172 (D.C. Cir. 2021).

Section 2000e(b) requires an employer to have at least fifteen employees for each working day in twenty or more weeks of the current or preceding calendar year; the plaintiff bears the burden of proving that threshold.

Carbajal v. Hayes Management Services, Inc. · filed 2023-12-04(b)

An employer is only subject to Title VII of the Civil Rights Act if it “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). This “numerosity” requirement is an element of Carbajal’s Title VII claim that she must prove at trial.

Section 2000e(b) requires an employer to have at least 15 employees for each working day in 20 or more weeks of the current or preceding year; that threshold is an element of a Title VII claim, not a jurisdictional requirement.

Moore v. I-55 Truckstop Restaurant, Inc. · filed 2025-02-24(b)

To be subject to Title VII, a company must have “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). This requirement is not jurisdictional, but an element of the “plaintiff's claim for relief.” Arbaugh v. Y&H Corp., 546 U.S. 500, 516 (2006). Therefore, this not a case where the Court can look to evidence outside the pleadings, as is permissible when resolving questions of jurisdiction.

Section 2000e(b) defines a Title VII employer as an entity with at least 15 employees for each working day in at least 20 calendar weeks in the current or preceding year.

Michaels v. Sasser's Glass Works Inc. · filed 2025-02-24(b)

Both statutes define “employer” as an entity that had “fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year” at the time of the alleged violation. ... The undisputed evidence showed that SGW did not qualify as an employer under either Title VII or the FCRA because it did not have the required number of employees.

Section 2000e(b) limits Title VII’s employer coverage to employers with at least 15 employees.

Kevin Harris, V. Cb Solutions, Llc & Daniel Allen · filed 2025-04-28(b)

But as CB Solutions pointed out at summary judgment, Title VII applies only to employers with 15 or more employees, see 42 U.S.C. § 2000e(b), and Harris did not dispute that CB Solutions had only 12 employees.

Section 2000e(b) limits Title VII claims to employers with at least fifteen employees for each working day in twenty or more calendar weeks in the current or preceding year.

Campbell v. Michael Buongiorne Construction Ink · filed 2025-06-27(b)

But Title VII claims can be brought only against those employers who have “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).

Section 2000e(b) defines a covered employer as one with at least fifteen employees for the required period.

Kribbeler v. Zen Enterprises Corporation · filed 2025-06-09(b)

“An employer who employs fewer than fifteen employees does not satisfy Title VII’s statutory definition of employer and, therefore, is not subject to discrimination actions founded on Title VII.”

Section 2000e(b) requires an employer to have at least fifteen employees for each working day in twenty or more calendar weeks of the current or preceding year to be covered by Title VII.

JENKINS v. LNL HOME SERVICES · filed 2025-07-22(b)

As such, the Court found that whether LNL had employment relationships with at least fifteen individuals for each of twenty or more weeks in 2020 and 2021 is a factual dispute best left for the jury. The Court will not grant summary judgment on Jenkins’ Title VII claims on this basis.

Disputed evidence about employee numbers can prevent summary judgment on whether an entity qualifies as an employer under § 2000e(b).

Erazo v. IGH Restoration LLC · filed 2025-08-08(b)

The Court finds that Defendants have not met their initial burden of demonstrating the absence of a genuine issue of material fact, and in opposition, Erazo has identified evidence from which a reasonable jury could infer that IGH qualifies as an employer under Title VII.

Title VII’s employer definition requires at least fifteen employees.

Fountain · filed 2026-04-16(b)

Here, Title VII’s fifteen-employee requirement applies, and Plaintiff has offered no facts establishing Cerreto meets that threshold. See 42 U.S.C. § 2000e(b).

Section 2000e(b) limits Title VII coverage to employers with at least fifteen employees.

El Karmassi v. Lot Corporation · filed 2026-06-03(b)

Assuming El Karmassi was an employee, relief under Title VII is only available against employers with fifteen or more employees. 42 U.S.C. §§ 2000e(b), 2000e-2(a)(1); Arbaugh v. Y & H Corp., 546 U.S. 500, 503, 515-16 (2006). At the evidentiary hearing, El Karmassi testified that Defendant, at full staff, consisted of twelve employees. On this fact alone, El Karmassi fails to allege a legitimate cause of action under Title VII.

Section 2000e covers an employer with more than 25 employees that operates in an industry affecting commerce.

Equal Employment Opportunity Commission v. Georgia-Pacific Corp. · filed 1977-12-08(b), (g), and (h)

During all times pertinent to this action, Georgia-Pacific has been and is now an employer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g), and (h) of Title VII, 42 U.S.C.A. §§ 2000e(b), (g) and (h). Georgia-Pacific has continuously since at least July 2, 1965, and does now, employ more than 25 people.

Section 2000e(b) defines which employers are covered by Title VII.

Mixon v. Hanley Industries, Inc. · filed 1978-07-17(b)

At all times relevant herein, defendant was an employer within the meaning of 42 U.S.C. § 2000e(b).

Section 2000e(b) defines who qualifies as an employer under Title VII; TWA qualifies.

Furr v. Trans World Airlines, Inc. · filed 1978-09-05(b)

Defendant Trans World Airlines, Inc. (T.W.A.), is a Delaware corporation authorized to do business in Ohio and is an employer within the meaning of 42 U.S.C. § 2000e(b).

Section 2000e(b) defines which employers are covered by Title VII, including employers with more than fifteen employees engaged in an industry affecting commerce.

Burwell v. Eastern Air Lines, Inc. · filed 1978-09-06(b)

Eastern employs more than fifteen persons and has, at all times material to this action, been an employer engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(b), (g) and (h).

Section 2000e(b) defines which employers are covered by Title VII based on their connection to commerce and number of employees.

Cullari v. East-West Gateway Coordinating Council · filed 1978-09-18(b)

Defendant is an employer engaged in an industry affecting commerce and has employed at least 25 employees at all times relevant to this action.

Section 2000e defines the terms used to determine whether an employer is engaged in an industry affecting commerce under Title VII.

EEOC v. Contour Chair Lounge Co., Inc. · filed 1978-09-28(b), (g), (h)

Defendant Contour Chair Lounge Company, Inc. is a corporation doing business within the state of Missouri and is an employer engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(b), (g) and (h).

Section 2000e defines employers and industries affecting commerce covered by Title VII.

Harris v. Anaconda Aluminum Co. · filed 1979-03-30(b), (g), (h)

It has continuously employed several hundred persons in those operations since prior to July 2, 1965, the effective date of Title VII, and is therefore an employer engaged in an industry affecting commerce within the meaning of section 701(b), (g) and (h) of Title VII, 42 U.S.C. § 2000e-1(b), (g) and (h).

Section 2000e(b) defines the employers covered by Title VII.

Williams v. St. Louis Diecasting Corp. · filed 1979-05-21(b)

At all times relevant herein, defendant has been doing business within this District, and is an employer within the meaning of 42 U.S.C. § 2000e(b).

Section 2000e defines employer, commerce, and industry affecting commerce for Title VII coverage.

Martin v. Frontier Federal Savings & Loan Ass'n · filed 1981-04-06(b), (g), (h)

For several years, the defendant has continuously been and is now an employer engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. § 2000e(b), (g), and (h).

Section 2000e defines the employers and labor organizations covered by Title VII.

Bowe v. Colgate-Palmolive Company · filed 1967-09-12(b), (d)

Colgate was an “employer” and the defendant Union was a “labor organization” within the meaning of Title VII of the Civil Rights Act of 1964.

Section 2000e's definition of a labor organization includes these local trade unions.

United States v. Sheet Metal Wkrs. Int. Ass'n, LU No. 36 · filed 1968-03-07(d)

Both are labor organizations as defined by 42 U.S.C. § 2000e, and both are within the scope of 42 U.S.C. § 2000e-2(c).

Section 2000e defines “employer,” “commerce,” and “industry affecting commerce” for determining Title VII coverage.

Equal Employment Opportunity Commission v. E. I. duPont De Nemours & Co. · filed 1978-01-25(b), (g), (h)

Since July 2, 1965, the effective date of Title VII, DuPont has continuously been an employer engaged in an industry affecting commerce within the meaning of Section 701(b), (g) and (h) of Title VII, 42 U.S.C. § 2000e(b), (g) and (h), and has employed more than twenty-five persons.

Section 2000e(b) defines which employers are covered by Title VII.

Hoard v. Teletype Corp. · filed 1978-05-08(b)

At all times material to this action, Teletype has been an employer within the contemplation of 42 U.S.C. § 2000e(b).

Section 2000e(b) defines a covered employer as one engaged in an industry affecting commerce with at least fifteen employees for each working day in twenty or more calendar weeks.

Stastny v. Southern Bell Telephone & Telegraph Co. · filed 1978-05-12(b)

4. The defendant is an employer engaged in an industry affecting commerce, and has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar years, within the meaning of 42 U.S.C. § 2000e(b).

Section 2000e’s definitions determine whether a company qualifies as an employer under Title VII.

Equal Employment Opportunity Commission v. Credit Consultants, Inc. · filed 1981-08-26(b), (g), (h)

The defendant, Credit Consultants, Inc., is an employer within the meaning of § 701(b), (g), and (h) of Title VII, 42 U.S.C. § 2000e(b), (g), and (h), and the defendant, Robert Bernstein, is the president of the defendant company.

Section 2000e(b)'s definition of employer covers Barber-Scotia College.

Turner v. Barber-Scotia College · filed 1985-03-12(b)

Defendant Barber-Scotia College (BSC) is an institution of higher learning and is an employer within the meaning of Title VII of the Civil Rights Act of 1964.

Section 2000e(b) covers a county transportation agency as an employer under Title VII.

Johnson v. Transportation Agency · filed 1985-09-05(b)

Established and maintained by the County of Santa Clara, California, the Agency is an employer within the meaning of Title VII, 42 U.S.C. Sec. 2000e(b).

Section 2000e defines which employers are covered by Title VII.

Williams v. HEALTH MAINTENANCE ORG. OF FLORIDA · filed 1988-03-01(b)

Defendant, HMO of Florida (HMOFL) is an employer within the meaning of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.

Section 2000e(b) defines which employers are covered by Title VII.

Shrout v. Black Clawson Co. · filed 1988-04-13(b)

Black Clawson, an employer within the meaning of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, had corporate data processing facilities in Middletown.

A school district can qualify as an employer under § 2000e.

Brooks v. Fonda-Fultonville Central School District · filed 1996-08-30(b)

Plaintiff is a woman, and the School District is an employer within the meaning of 42 U.S.C. § 2000e.

Section 2000e defines the employers, labor organizations, and their agents covered by Title VII.

Saidin v. New York City Department of Education · filed 2007-07-27

Finally, the facts Saidin asserts in the Amended Complaint are insufficient to plead a claim against PEHS under Title VII, the ADEA or the ADA, as PEHS was not Saidin’s employer or union or an agent of the employer or union and had no direct involvement in any aspect of the unlawful employment discrimination Saidin alleges.

State legislative chambers that employ the plaintiffs are proper Title VII defendants.

DaSilva v. State of Indiana · filed 2022-04-06(b)

No, the right defendants under Title VII are the plaintiffs’ employers, here the House and Senate, which may be found liable for failing to use the mechanisms at their dis- posal for the protection of their employees.

Section 2000e(b)'s employer definition turns on economic realities, agency principles, and the defendant's control over the worker, even when a temporary agency technically employs the worker.

Reynolds v. CSX Transportation, Inc. · filed 1997-06-20(b)

We have held that whether a defendant is an "employer" for Title VII purposes is based on the "economic realities" of the situation "viewed in light of the common law principles of agency and the right of the employer to control the employee." ... Reynolds produced legally sufficient evidence to show that CSXT was her employer for Title VII purposes.

Section 2000e(b) defines an employer as a person with at least fifteen employees during the required period and includes the person's agents.

Hogue v. Roach · filed 1997-06-23(b)

For Title VII purposes, an employer 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____”

Section 2000e(f) defines an employee as an individual employed by an employer, and a partner qualifies only when the actual relationship closely resembles employment under federal law.

Margarita SERAPION, Plaintiff, Appellant, v. Fred H. MARTINEZ, Et Al., Defendants, Appellees · filed 1997-07-18(f)

Title VII defines an employee only as “an individual employed by an employer,” 42 U.S.C. § 2000e(f), a turn of phrase which chases its own tail. ... We think that the reverse is true: whether an individual is an employee for purposes of Title VII is a matter of federal law, and the question must be answered with reference to principles of federal law. ... Thus, we hold that the meaning of the term “employee,” as that term is used in Title VII, must be derived through an analysis of federal statutes, legislative history, judicial decisions, and common law understandings, not through the law of Puerto Rico.

Section 2000e(b) defines an employer as a person with at least fifteen employees and that person’s agents, while Title VII liability for individual agents is limited to nondelegable duties.

Emmons v. Rose's Stores, Inc. · filed 1997-10-20(b)

An “employer” is defined 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(b). ... The overwhelming weight of this persuasive authority, and the Fourth Circuit’s apparent move away from its Paroline logic, convinces this Court that individual agents and employees cannot be held liable under Title VII for the delegable duties which they perform.

Title VII’s definition of employer does not make individual employees liable for discrimination.

Ransom v. State of Arizona Board of Regents · filed 1997-10-22(b)

Under Title VII and the ADEA, however, an individual employee is not an “employer” for purposes of liability.

Section 2000e’s definition of employer excludes individuals who were not the plaintiff’s employer from Title VII liability.

Gomez v. Pellicone · filed 1997-11-20(b)

In addition, they are not subject to suit under Title VII because they were not Gomez’ employer.

Section 2000e(b) counts temporary agency workers toward the 15-employee threshold only if the employer exercises control over them.

Burdett v. Abrasive Engineering & Technology, Inc. · filed 1997-10-31(b)

Only those agency employees over whom Abrasive exercised control may be considered Abrasive’s employees.

Section 2000e(b) allows multiple government entities to be treated as a single Title VII employer when the NLRB factors support aggregation.

Lyes v. City of Riviera Beach, FL · filed 1997-11-05(b)

Accordingly, because treating public and private employers alike comports with Title VII and because Dumas is not to the contrary, we hold that the NLRB factors must inform a court’s inquiry when a plaintiff alleges that multiple governmental entities acted as a single employer and in a discriminatory fashion.

Section 2000e(b) requires an employer to have at least 15 employees for Title VII coverage, and a plaintiff must provide evidence of that threshold when it is challenged.

Rohde v. Rippy Surveying Co · filed 1997-11-26(b)

The district court dismissed Rohde’s claim against Rippy Surveying Company under FED. R. CIV. P. 12(b)(1) because Rohde failed to produce competent evidence that Rippy Surveying Company had at least 15 employees))a necessary requirement for subject matter jurisdiction in a Title VII claim. ... We AFFIRM.

Section 2000e(b)'s definition of employer can treat separate entities as a single employer when their ownership and operations are sufficiently integrated.

Equal Employment Opportunity Commission v. Oak Lawn Ltd. II · filed 1997-12-01(b)

Since the ADEA was modeled after Title VII and its definition of employer is almost identical, I find that this doctrine can also be applied to Title VII cases.

Section 2000e’s circular definition of “employee” calls for common law agency principles to distinguish employees from independent contractors.

Tagare v. NYNEX Network Systems Co. · filed 1997-12-08(f)

Because Title VII contains only a circular definition of “employee,” O’Connor, 126 F.3d at 115; Stetka, 859 F.Supp. at 666, we look to common law agency principles to determine whether Tagare was an employee or independent contractor.

Section 2000e(b) excludes Indian tribes from Title VII’s definition of employer, including a school board established and controlled by tribal members.

Giedosh v. Little Wound School Board, Inc. · filed 1997-12-18(b)

Based upon this Court’s factual findings, this Court holds that as a matter of law the definition of an “Indian tribe” under Title VII and the ADA includes a school board which is established and controlled by individuals of the Tribe.

Section 2000e(b) requires at least fifteen employees for at least twenty weeks for an entity to qualify as a Title VII employer.

Hoar v. Prescott Park Arts Festival · filed 1998-01-26(b)

Based on the record presented, plaintiff has not sustained his burden to show that Prescott Park had at least fifteen employees for at least twenty weeks in either 1994 or 1995. Accordingly, the court concludes that Prescott Park was not an “employer” within the meaning of Title V I I , and this court lacks subject matter jurisdiction over plaintiff’s suit.

Section 2000e defines an employer to include a person with at least fifteen employees and that person's agents; an individual employee or supervisor who does not otherwise qualify as an employer is not personally liable under Title VII.

Ashiegbu v. Purviance · filed 1998-04-16(b)

Under the Title VII, “an individual employee/supervisor who does not otherwise qualify as an ‘employer’ may not be held personally liable under Title VII.” ... An employer is defined as “a person engaged in an industry affecting commerce who has fifteen or more employees ... and any agent of such person.” ... In this case, Plaintiff fails to allege that the Individual State Defendants meet the statutory definition of employer. Accordingly, the Court finds that Plaintiff can allege no set of facts that would entitle him to relief on his claims against the Individual State Defendants for violations of Title VII.

Section 2000e(f) uses common-law agency principles to determine employee status, with particular attention to whether the alleged employer controls the worker’s performance.

Zinn v. McKune · filed 1998-05-12(f)

In Lambertsen, we held that the skeletal definitions of “employer” and “employee” provided in 42 U.S.C. § 2000e(b) and (f) should be fleshed out by applying common-law agency principles to the facts and circumstances surrounding the working relationship of the parties. ... No evidence establishes the requisite degree of control over Ms. Zinn’s professional nursing services necessary to support a finding that Ms. Zinn was an employee of the Department.

Section 2000e’s definition of employee is read broadly for retaliation claims when a covered employer controls a person’s employment opportunities with another employer.

Diana v. Schlosser · filed 1998-09-14(f)

This court agrees that the definition of employee, ... as it is used in § 2000e-3, should be viewed in light of the broad remedial purpose of Title VII as a whole. ... Accordingly, Diana may pursue a retaliation claim against WCCC under Title VII, even though WCCC was not her employer.

An individual supervisor who does not meet Title VII’s definition of an employer cannot be personally liable under the statute.

Kelley v. Worley · filed 1998-12-14(b)

Defendant Worley, who does not meet the definition of an “employer” under Title VII, cannot be liable to Plaintiff under this statute.

Section 2000e(b) treats a person as an employer through an agent only when the agent acts for that person with respect to employment practices.

Nixon v. Northwestern Mutual Life Insurance · filed 1999-07-15(b)

Although Coopersmith is defendant’s agent with respect to sales of life insurance policies, there is no evidence that he is an agent of defendant with respect to plaintiffs employment.

An independent consultant who is not an employer’s agent is not the plaintiff’s employer under Title VII.

McMenemy v. City of Rochester · filed 1999-09-14(b)

However, the Court disagrees and, as stated above, finds that Abrams was not an agent of the City, but, rather, an independent consultant, and, therefore, not the plaintiffs “employer.”

When deciding whether separate businesses count as one Title VII employer, courts give particular weight to centralized control of labor operations.

Alberter v. McDonald's Corp. · filed 1999-09-20(b)

Because the application of the four-part test in the Title VII context necessarily involves claims of employment discrimination by the entities involved, it makes sense to place greater weight on the third of these factors, centralized control of labor operations.

A company may qualify as a Title VII employer when it significantly affects a worker’s employment opportunities, even if another company pays the worker.

Bampoe v. Coach Stores, Inc. · filed 2000-03-30(b)

Here, plaintiffs allegations are sufficient to bring Coach within the definition of “employer.” The Court finds that plaintiff was an employee of Coach for Title VII purposes.

Section 2000e’s definition of employer places Title VII liability on the employer rather than individual supervisors.

Kramer v. Galleon Armored Car · filed 2000-06-20(b)

... the district court held that, in this circuit, Title VII liability is borne by employers and not individual supervisors. ... we agree with the district court’s disposition of plaintiff’s Title VII claims against Tenny and Nielson.

Section 2000e defines an employer for Title VII coverage as a person engaged in an industry affecting commerce who employs at least 15 employees for at least 20 weeks in the relevant year.

Miranda v. BBII Acquisition Corp. · filed 2000-10-16(b)

Specifically, the term employer refers to a person engaged in an industry affecting commerce, employing fifteen (15) or more employees for twenty (20) or more weeks in the current preceding calendar year from the date of the alleged discriminatory act. ... Therefore, Plaintiffs claim against under Title VII Defendants in their individual capacity are hereby DISMISSED.

Section 2000e(b) defines an employer for Title VII purposes, and a shareholder's status alone does not make him an employer.

Collins v. Franklin · filed 2000-11-03(b)

The defendant is correct that circuit precedent precludes individual employee or supervisor liability for sexual harassment under Title VII. ... While Franklin is also alleged to be a shareholder, that alone does not make him an employer.

Section 2000e(b) excludes an individual recruiter from Title VII's definition of an employer.

Kenney v. Musgreves · filed 2000-11-07(b)

We agree that dismissal as to Mr. Grable was proper because he was not an employer under Title VII.