42 U.S.C. § 2000e

Section 2000e(n)'s definition of “respondent” does not automatically determine a union's compensatory damages cap under § 1981a(b).

Dowd v. United Steelworkers · filed 2001-06-15(n)

We decline to insert the definition of "respondent" in §2000e(n) mechanically into the damages-cap provision in § 1981a(b).

Section 2000e(n) defines “respondent” to include a federal entity subject to section 717.

Velez v. Roche · filed 2004-06-30(n)

The word “respondent” is defined in 42 U.S.C § 2000e as “an employer, employment agency, labor organization, joint labor-management committee controlling apprenticeship or other training or retraining program, including an on-the-job training program, or Federal entity subject to section 717.” Id. § 2000e(n) (emphasis added). The Court therefore orders that the jury award should be reduced to $300,000 to reflect Title VIPs statutory cap.

Section 2000e(n) defines “respondent” to include a federal entity subject to § 2000e-16, bringing that entity within Title VII’s prohibition on discriminatory cutoff scores.

Bauer v. Lynch · filed 2016-01-11(n)

Section 2000e-(2)(l)’s discriminatory cutoff score prohibition applies to “a respondent,” which includes a “Federal entity subject to section 2000e-16.” See 42 U.S.C. § 2000e(n).

Section 2000e(c) defines an employment agency by whether it regularly procures employees or employment opportunities; a jury may decide whether that requirement is met.

Axness v. Aqreva LLC · filed 2015-07-27(c)

Similar to the definitional determination a jury may be asked to make as to an “employer,” whether an entity acts with sufficient regularity as an “employment agency” for purposes of Title VII is also a proper question for the jury.

Section 2000e defines employers and employment agencies covered by Title VII.

Scaglione v. Chappaqua Central School District · filed 2002-07-11(b), (c)

An “employer” is defined (in relevant part) 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.” § 2000e(b). ... Title VII defines an employment agency (in relevant part) as “any person regularly undertaking with or without compensation to procure employees for an employer or to procure for employees opportunities to work for an employer and includes an agent of such a person.” § 2000e(c). ... Following the line of reasoning established in Sibley and Spirt, WCPO would qualify as an “employment agency” pursuant to Title VII.

Section 2000e limits Title VII causes of action to employers, employment agencies, and labor organizations.

Jakomas v. McFalls · filed 2002-10-31(a), (b), (c)

This is a crucial inquiry under Title VII, which provides a cause of action only against employers, employment agencies, and labor organizations. 42 U.S.C. § 2000e (a), (2)(b) and (c).

Section 2000e(c) defines an employment agency as a person who regularly procures employees for employers or job opportunities for employees; a state personnel department whose statutory duties do not include that work does not qualify.

Figueroa v. City of Camden · filed 2008-10-02(c)

Title VII defines an “employment agency” as “any person regularly undertaking with or without compensation to procure employees for an employer or to procure for employees opportunities to work for an employer and includes an agent of such a person.” 42 U.S.C. § 2000e(c). ... However, despite Plaintiffs’ creative argument, the NJDOP has specific duties established by statute, and acting as an employment agency is simply not one of them.

A training program may qualify as an employment agency when it regularly helps participants obtain work with employers covered by Title VII.

Wilborn v. SOUTHERN UNION STATE COMMUNITY COLLEGE · filed 2010-03-30(c)

Presented with the evidence above, a reasonable jury could conclude that the Truck Program “regularly undertook] ... to procure for employees opportunities to work” for trucking companies.

Section 2000e defines an employment agency as a person who regularly procures employees for employers or job opportunities for employees, with or without compensation.

Katz v. Adecco USA, Inc. · filed 2012-01-10(c)

An employment agency is “any person regularly undertaking with or without compensation to procure employees for an employer or to procure for employees opportunities to work for an employer.” 42 U.S.C. §§ 2000e, 12111(7). There is no dispute that Adecco is an employment agency.

Foreign citizens based abroad who work exclusively outside the United States do not count toward Title VII’s fifteen-employee minimum.

Mousa v. Lauda Air Luftfahrt, A.G. · filed 2003-03-31(f)

42 U.S.C. § 2000e(f) supports this reading of the statute. If the definition of “employee” included all individuals working abroad, there would be no reason for Congress to expressly include United States citizens. Accordingly, the Court finds that foreign citizens based abroad who worked exclusively outside of the United States are not included in the fifteen-employee jurisdictional count.

Section 2000e(f) does not prohibit counting foreign employees of a U.S.-controlled corporation toward Title VII’s fifteen-employee coverage threshold.

Kang v. U. Lim America, Inc., Tae Jin Yoon, Does 1-100 · filed 2002-07-15(f)

The statutory definition is inclusive rather than restrictive. The term "employee" is defined to include U.S. citizens employed by U.S. companies in foreign countries rather than to prohibit counting non-U.S. citizens.

Section 2000e(b) excludes foreign citizens employed outside the United States when counting employees toward Title VII’s fifteen-employee threshold.

Davenport v. HansaWorld USA, Inc. · filed 2014-05-20(b)

As a result, the Court holds that foreign citizens employed outside the United States are excluded from the employee head count under 42 U.S.C. § 2000e(b).

Section 2000e’s definition of employer allows related companies to be treated as one employer under Title VII when their operations and control of employment decisions are sufficiently integrated.

U.S. Equal Employment Opportunity Commission v. Lindsay Ford LLC · filed 2021-11-02(b)

On this record, where the undisputed facts reveal that all of the factors are consistent with an integrated enterprise, and that Lindsay Ford and Lindsay Management were both deeply involved in the employment decisions at issue here, the Court concludes that the two operated as an integrated enterprise.

Affiliated businesses’ employees are not aggregated to meet Title VII’s fifteen-employee threshold on a veil-piercing theory merely because the businesses share operations; their treatment of corporate formalities must warrant piercing the veil.

Prince v. Appleton Auto LLC · filed 2020-10-21(b)

Here, there is no evidence the defendants neglected corporate forms or risked confusing creditors. While substantially integrated, the dealerships properly maintained separate accounts, identities, and corpo- rate records. In this case, there is no basis to pierce the corpo- rate veil.

Section 2000e(b) allows employees of related businesses to be counted together toward the employer threshold when the businesses form an integrated enterprise.

Gilliland v. Sanico Clanton, LLC (CONSENT) · filed 2019-11-04(b)

Accordingly, the Court concludes that Sanico does not qualify as an integrated enterprise, and therefore, aggregating them for purposes of qualifying as an “employer” under Title VII is inappropriate.

Section 2000e(b) allows employees of integrated companies, including employees abroad, to be counted together toward Title VII’s fifteen-employee threshold.

Arroyo-Pérez v. Demir Group International · filed 2011-01-11(b)

Therefore, I find that both companies should be counted together for the purpose of determining whether the defendants meet the Title VII numerosity requirement.

Section 2000e(b) permits related companies to be treated as a single employer based on their operations, management, control of labor relations, and ownership and financial control.

Tawwaab v. Virginia Linen Service, Inc. · filed 2010-07-28(b)

To determine whether two entities constitute a single employer or integrated enterprise, courts consider four factors: (1) the interrelation of operations; (2) whether there is common management; (3) whether there is centralized control of labor relations; and (4) whether there is common ownership and financial control.

Common board members alone did not make the two companies integrated employers under Title VII.

DePaoli v. Vacation Sales Associates, LLC · filed 2005-11-04(b)

While Breeden and VSA are sufficiently linked through common board members, they are not integrated employers for the purposes of Title VII.

Related corporations may count as one Title VII employer when they are sufficiently integrated, with particular attention to who made the employment decision.

Torres v. Liberto Mfg Co Inc · filed 2003-05-13(b)

This theory is based on this Circuit’s broad definition of the term “employer” that includes superficially distinct entities that are sufficiently interrelated so as to constitute a single, integrated enterprise. Lusk v. Foxmeyer Health Corp., 129 F.3d 773, 777 (5th Cir. 1997). ... This analysis ultimately focuses on the question of whether the parent corporation was a ... 7 ... final decision-maker in connection with the employment matters underlying the litigation.

Section 2000e(b) requires an employer to have at least 15 employees for Title VII coverage; interconnected employers may be treated as an integrated enterprise to meet that threshold.

Anderson v. Pacific Maritime Ass'n · filed 2003-07-17(b)

A plaintiff with an otherwise cognizable Title VII claim against an employer with less than 15 employees may assert that the employer is so interconnected with another employer that the two form an integrated enterprise, and that collectively this enterprise meets the 15-employee minimum standard.

Two distinct government agencies do not become one Title VII employer merely because they share a program goal.

Strauss v. New York State Department of Education · filed 2005-12-15(b)

In our view, the creation by the Legislature of a program that utilizes the talents of two distinct agencies to realize a singular goal does not, without more, merge the agencies for title VII purposes.

Overlapping employees and informal advice do not make one corporation liable under Title VII for another corporation’s employment decision when the latter controlled that process.

Williams v. Massachusetts Mutual Life Insurance · filed 2007-02-20(b)

Here, Babson exercised complete control over the employment process in relation to Plaintiff; MassMutual had no role whatsoever. The fact that overlapping employees may have had a role in consulting with Plaintiff to assist him in finding new employment, or may have generally been available for inquiries or complaints about job discrimination, cannot make MassMutual liable for an allegedly discriminatory decision that, if made at all, was made solely by Babson employees.

Related entities may be treated as a single employer for Title VII’s fifteen-employee threshold when their operations, labor relations, management, and ownership support that finding.

Equal Employment Opportunity Commission v. SDI Athens East, LLC · filed 2010-02-17(b)

It is undisputed that TomCo employs less than fifteen employees as required to be an “employer” under 42 U.S.C. § 2000e(b) (Thomas Dep. 17:11-13), and that McKillip failed to file an EEOC Charge of Discrimination against TomCo (see EEOC Charge of Discrimination). ... Examining the four factors in this case, the Court finds that the evidence in the present record is sufficient for a reasonable factfinder to conclude that TomCo and SDI Athens are a single employer for Title VII purposes.

Related companies may be treated as a single Title VII employer based on their operations, management, control of labor relations, and ownership or financial control.

Sears v. Magnolia Plumbing, Inc. · filed 2011-04-21(b)

While sparse, the factual allegations of the complaint — and the information judicially noticed regarding the composition of the corporate defendants’ Boards of Directors — render it “plausible” that Joseph J. Magnolia, Inc. and Magnolia Plumbing, Inc. may be regarded as a “single employer” for liability purposes.

Section 2000e(b) can treat separate businesses as one Title VII employer when their management, operations, labor relations, and ownership are sufficiently integrated.

Gilbert v. Freshbikes, LLC · filed 2014-07-09(b)

In sum, Plaintiff has alleged sufficient facts to survive the motion to dismiss on the question of Freshbikes’ single employer status under Title VII at this preliminary stage of the proceedings.

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

Davis v. Ricketts · filed 2014-08-27(b)

Because we agree with the district court that Hugo and OEF are not sufficiently integrated enterprises to combine their employees to meet the statutory numerosity requirement, the Appellants’ Title VII and NFEPA claims cannot survive and we affirm the grant of summary judgment.

Sufficiently integrated entities can be treated as a single employer under Title VII.

Mathews v. Happy Valley Conference Center, Inc. · filed 2019-12-12(b)

The jury found that Title VII applied because Happy Valley and the Church were so interrelated that they constituted a single employer. ... As we have previously discussed, substantial evidence supports the jury’s single employer finding.

Section 2000e(b) permits a franchisor and franchisee to be treated as a single employer when they operate as an integrated enterprise.

McLaughlin v. Owasso Wings LLC · filed 2021-11-24(b)

Under Title VII, an employer is defined as “a person engaged in an industry affecting commerce who has fifteen or more employees.” 42 U.S.C. § 2000e(b). ... Plaintiff’s Petition is void of any allegations that would establish that Owasso Wings and BWW are an integrated enterprise for Title VII purposes.

Entities may be treated as a single employer under Title VII when they share centralized control of labor relations, even if the other integration factors are absent.

Houston v. Memphis Light Gas & Water Division · filed 2022-03-28(b)

Because all four factors need not be met in every case and centralized control of labor is a central concern, Houston has plausibly stated that Local Union 1288 and MLGW constitute a single employer for purposes of Title VII.

Section 2000e’s employer definition can cover a parent company under a single-employer theory when the parent sufficiently participates in employment decisions.

Cassard · filed 2025-11-19(b)

Based on the analysis above, the Amended Complaint fails to allege facts that would support a plausible claim that OGI acted as a single employer with the remaining Defendants under the Cook factors. Cassard has thus failed to plead that OGI was her employer, a necessary element for all of her employment claims.

Section 2000e(g)'s definition of commerce includes U.S. possessions, including Johnston Island.

Equal Employment Opportunity Commission v. Raytheon Technical Services Co. · filed 2004-03-12(g)

The parties do not dispute that Johnston Island is a possession of the United States. Consequently, construing the statute broadly, the court concludes that Johnston Island is included within the coverage of Title VII.

The definition of “employer” permits liability when a biased subordinate’s actions cause an adverse employment decision, even if that subordinate lacks decisionmaking authority.

Equal Employment Opportunity Commission v. BCI Coca-Cola Bottling Co. · filed 2006-06-07(b)

Instead, the statute imposes ... liability for discrimination by employers and their agents, 42 U.S.C. § 2000e(b), which in accordance with agency law principles includes not only “decisionmakers” but other agents whose actions, aided by the agency relation, cause injury.

Section 2000e(k) does not require employers to cover contraception because contraception is not a medical condition related to pregnancy.

Standridge v. Union Pacific Railroad · filed 2007-03-15(k)

Following Krauel, we hold that contraception is not “related to” pregnancy for PDA purposes because, like infertility treatments, contraception is a treatment that is only indicated prior to pregnancy.

Section 2000e(k) includes abortion within “related medical conditions,” protecting employees from discrimination because they have had an abortion.

Doe v. C.A.R.S Protection Plus, Inc. · filed 2008-05-30(k)

Clearly, the plain language of the statute, together with the legislative history and the EEOC guidelines, support a conclusion that an employer may not discriminate against a woman employee because she has exercised her right to have an abortion. We now hold that the term “related medical conditions” includes an abortion.

Section 2000e(k)(2) covers lactation as a medical condition related to childbirth.

Allen-Brown v. District of Columbia · filed 2016-03-31(k)(2)

Thus, as a matter of plain language, the PDA applies to lactation.

Section 2000e(k) treats lactation as a medical condition related to pregnancy and therefore covered by Title VII.

Mayer v. Professional Ambulance, LLC · filed 2016-09-30(k)

Absent contrary guidance from the First Circuit, this Court follows the Houston Funding decision and EEOC guidance, and finds that lactation is a medical condition related to pregnancy, and therefore covered under Title VII and RICRA.

Section 2000e(b)’s inclusion of an employer’s agents does not give a municipal department capacity to be sued when other law denies it that capacity.

Jenkins v. Baltimore City Fire Department · filed 2012-03-30(b)

The Court finds no merit in plaintiffs’ argument that BCFD is an agent of the City and agents can be sued under Title VII. ... More importantly, Plaintiffs overlook the fact that Title VIPs exemptions are not the only applicable exemptions — other authorities for exemption exist, as made clear by case law cited above.

Section 2000e(b)’s inclusion of an employer’s agent does not give a municipal department independent capacity to be sued.

Darby v. Pasadena Police Department · filed 1991-08-23(b)

We do not agree with this reasoning. Congress, in enacting Title VII, created a cause of action for victims of discrimination. This made all covered employers liable for any discrimination that they might occasion. It did not, however, speak to whether a plaintiff should name a subdivision or the ultimate employer on the first page of his complaint, and it did not provide an exception to the normal rule that a government entity may choose the level at which it will pursue and defend all lawsuits involving it.

Section 2000e(f)'s elected official exclusion does not cover an applicant for an appointed position who has never been elected to office.

Lloyd v. Birkman · filed 2015-09-02(f)

Lloyd has never been elected. Although he could be elected in the future, the employment decision at the time of his application was completely separate from any election process. Accordingly, the Court holds that Lloyd does not fall within the elected official exemption to Title VII.

Section 2000e(f) excludes elected public officials from Title VII’s definition of “employee.”

Younge v. Berman · filed 2023-03-06(f)

Younge was not an “employee” under Title VII, so he is not a proper plaintiff. 42 U.S.C. §2000e(f) (“‘[E]mployee’ shall not include any person elected to public office in any State or political subdivision of any State by the qualified voters thereof”).

Section 2000e(f) includes U.S. citizens employed abroad within Title VII’s protection but excludes non-U.S. citizens employed abroad.

Kambala v. Checchi and Company Consulting, Inc. · filed 2017-12-01(f)

Thus, United States citizens working for covered employers outside of the country fall within the protections of Title VII, see 42 U.S.C. § 2000e(f), but similarity situated non-United States citizens do not, 42 U.S.C. § 2000e-1(a); see also 29 C.F.R. § 1614.103(d)(4) (stating that “[a]liens employed in positions, or who apply for positions, located outside the United States” are not protected).

Section 2000e(f) extends Title VII’s employee definition to U.S. citizens employed abroad, but does not extend protection to a noncitizen living abroad who applies for a U.S. job.

Nakhid v. American University · filed 2021-09-14(f)

Although Congress later amended Title VII to expand its reach to U.S. citizens employed abroad by U.S. employers, see 42 U.S.C. § 2000e(f), the statute continues to contain no affirmative expression of extraterritorial application to those in Plaintiff’s circumstances—a noncitizen, nonresident who applies for domestic employment from abroad.

Under ANCSA, the employer definition in § 2000e(b)(1) excludes Alaska Native corporations and affiliates in which they own at least 25 percent of the equity.

Abikar v. Bristol Bay Native Corp. · filed 2018-01-09(b)(1)

Because GTS and Workforce are "affiliates in which the Native Corporation owns not less than 25 per centum of the equity," GTS and Workforce are also excluded from the definition of "employer" under Title VII.

Section 2000e defines “person” and “employee” without excluding undocumented workers based on immigration status.

U.S. Equal Emp't Opportunity Comm'n v. Phase 2 Invs. Inc. · filed 2018-04-17

It did not restrict the class of persons who could bring such suits by citizenship or immigration status. The relevant statutory text remains unchanged.

Section 2000e(j) includes religious observance and practice within religion, so an employer can discriminate on that basis without knowing the employee’s specific religion.

Kennedy v. Berkel & Company Contractors, Inc. · filed 2018-07-24(j)

The defendants are wrong to argue that an employer must know an employee’s religion in order to discriminate against the employee on the basis of religion. An employer undoubtedly violates Title VII by firing an employee because the employee reads scripture even if the employer does not know what scripture the employee reads. See 42 U.S.C. § 2000e(j) (“The term ‘religion’ includes all aspects of religious observance and practice, as well as belief . . . .”).

Section 2000e’s definitions of employer and employee call for the common-law agency test to determine joint employer status under Title VII.

Eeoc v. Global Horizons, Inc · filed 2019-02-06(b), (f)

Under the statute, the term “employer” is defined (subject to exclusions not relevant here) 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 term “employee” is defined (again subject to exclusions not relevant here) as “an individual employed by an employer.” § 2000e(f). ... We conclude that the common-law agency test should be applied in the Title VII context as well.

Title VII does not impose individual liability on an employer’s agent, and an official-capacity claim against the agent is redundant when the employer is also sued.

Chaney v. Community Hospice of Baldwin County · filed 2019-02-07(b)

Turning to the merits of Stewart’s motion, this circuit’s case law clearly demonstrates that the statutes under which Chaney seeks recovery—Title VII, the ADA, and the ADEA—do not provide for individual liability.

Different Christian denominations are not categorically distinct protected classes under Title VII's definition of religion without supporting evidence of differences in religious observance, practice, or belief.

Lindsey v. Bridge Rehab, Inc. · filed 2019-03-18(j)

That said, Title VII defines "religion" as "all aspects of religious observance and practice, as well as belief." 42 U.S.C. § 2000e(j). ... And while a plaintiff would not necessarily have to present evidence of the differences between, for example, Christianity and Islam to show that Christians and Muslims belong to different protected classes, the court cannot say that the same categorical distinction applies to different Christian denominations without any supporting evidence.

Section 2000e(j)'s definition of religion can cover sincerely held beliefs even when an employee describes them as part of a culture.

Dockery v. Maryville Acad. · filed 2019-03-29(j)

Drawing all reasonable inferences in Plaintiff's favor, Plaintiff's testimony that he views his Judaism as his culture does not preclude a finding that Plaintiff has religious beliefs stemming from his Jewish culture.

Section 2000e(k) requires pregnant workers to be treated the same as nonpregnant workers similar in their ability or inability to work.

Wiedel v. Brentwood Extended Care & Rehab, LLC · filed 2025-01-13(k)

What is missing is any specific comparison between Ms. Wiedel and nonpregnant workers “similar in their ability or inability to work.”

Section 2000e(k) requires employers to treat workers affected by pregnancy the same as others similar in their ability or inability to work; a failure-to-accommodate claim requires evidence that the employer accommodated such workers.

BREWER v. KEY BANK N.A. · filed 2024-09-03(k)

A PDA failure to accommodate claim, which prohibits employers from discriminating in the way they treat pregnancy-related inability to work, is grounded in the PDA’s second clause, which states that “women affected by pregnancy . . . shall be treated the same for all employment-related purposes . . . as other persons not so affected but similar in their ability or inability to work.” Peifer v. Bd. of Prob. & Parole, 106 F.4th 270, 276 (3d Cir. 2024) (alterations in original) (quoting 42 U.S.C. § 2000e(k)) (citations omitted). ... Under all of these circumstances, we conclude that Brewer has failed to establish a prima facie case of pregnancy discrimination based on a failure to accommodate theory.

A disparate treatment claim over lactation breaks under § 2000e(k) requires evidence that the employer accommodated a similarly situated worker more favorably.

Bye v. MGM Resorts International, Inc. · filed 2021-12-16(k)

Because Plaintiff has not identified any comparators, she has not made out a prima facie case of disparate treatment based upon failure to accommodate, and Defendant’s request for summary judgment as to this claim should be granted.

Section 2000e(k) permits a pregnant employee to establish the comparator element of a prima facie accommodation claim by showing that the employer accommodated others similar in their ability or inability to work.

Rios v. Leprino Foods Company · filed 2021-09-09(k)

At this stage, Plaintiff need only assert that Defendant accommodated others similar in ability or inability to work.

Section 2000e(k) requires a pregnant worker alleging unequal accommodation to identify someone similar in ability to work whom the employer accommodated.

Gilbert v. Kroger Co · filed 2020-05-19(k)

Without a comparator, Gilbert cannot establish a prima facie case of discrimination based on an alleged failure to provide a reasonable accommodation.

Section 2000e(k) requires pregnant workers to be treated the same as other workers similar in their ability or inability to work.

Barton v. Warren County · filed 2020-08-07(k)

Although Plaintiff Barton has pled facts plausibly suggesting that she is a member of a protected class, that she sought accommodation, and that Defendant County did not accommodate her, she has not pled any facts plausibly suggesting how Defendant County reasonably accommodated other corrections officers “similar in their ability or inability to work” to Plaintiff Barton.

Section 2000e(k) does not impose a heightened burden requiring an employer to explain why it excluded pregnant workers from an accommodation.

EEOC v. Wal-Mart Stores East, L.P. · filed 2022-08-16(k)

The second clause of the Act clarifies that pregnant women must “be treated the same” as others “similar in their ability or inability to work,” but it is a long stretch to say that this text requires a particular, height- ened burden on employers in Young’s step two. 42 U.S.C. § 2000e(k).

A pregnancy accommodation claim requires evidence that the employer accommodated other workers similar in their ability or inability to work.

Carmona v. DeJoy · filed 2022-11-09(k)

Carmona has not shown that defendants provided accommodations to other USPS rural carriers who similarly were unable to work a full eight-hour day and lift objects greater than ten pounds for the same duration as plaintiff.

Section 2000e(k) requires a pregnant worker claiming a failure to accommodate to identify a nonpregnant worker with a similar ability or inability to work who received an accommodation.

Gossett v. Jason's Deli · filed 2024-11-26(k)

Without a comparator, “similar in their ability or inability to work” required by 42 U.S.C. § 2000e(k), Gossett has not met the burden on her prima facie case and Jason’s Deli is entitled to summary judgment.

A successor may be liable for its predecessor’s Title VII violations even if the successor does not meet the fifteen-employee definition of an employer.

Equal Employment Opportunity Commission v. Georgina's LLC · filed 2020-12-04(b)

As such, the EEOC’s claim against Little G’s does not necessarily require that Little G’s meet the statutory definition of employer in Title VII.

Section 2000e(m) defines “demonstrate” to require both the burden of production and the burden of persuasion.

Bart v. Golub Corp. · filed 2024-03-26(m)

Congress also defined the term “demonstrate” to encompass both the burden of production and the burden of persuasion, 42 U.S.C. § 2000e(m), effectively overturning Price Waterhouse insofar as it held that the defendant-employer ever carries the burden of persuasion in a Title VII disparate treatment case.

Section 2000e(j)'s undue hardship defense is assessed using the information available to the employer when it denied the religious accommodation and terminated the employee.

Snow v. Women's HealthCare Associates, LLC · filed 2024-08-02(j)

Further, like in MacDonald, this Court holds that undue hardship is properly viewed at the time the employer decided to deny an employee’s requested religious exemption and then terminate his or her employment for refusing to obtain the COVID-19 vaccine.

The undue hardship defense is part of § 2000e(j), but this court could not resolve the employer’s defense without further factual development.

Williams v. UMass Memorial HealthAlliance - Clinton Hospital, Inc. · filed 2024-09-30(j)

“The undue hardship defense is built into the statutory definition of ‘religion,’ see 42 U.S.C. § 2000e(j), such that an employment action cannot constitute discrimination on the basis of religion, and an employer cannot be liable under Title VII for religious discrimination, if the undue hardship defense applies.” ... Like Plaintiff’s religious discrimination claim, the issue of whether Defendant would suffer undue hardship by granting religious accommodation involves the development of more facts on the record that cannot be resolved at this stage.

Section 2000e(j) requires employers to accommodate employees’ religious practices unless doing so would impose substantial costs in relation to the employer’s business.

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

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

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

Yockey v. Greater Baltimore Medical Center, Inc. · filed 2025-03-18(j)

Ms. Yockey’s failure-to-accommodate claim fails because the undisputed evidence establishes that GBMC could not have accommodated her vaccination exemption without undue hardship. Title VII does not require an employer to grant a religious accommodation if doing so would create an “undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would impose substantial increased costs in relation to its business.

Maki v. Federal Reserve Bank of Minneapolis · filed 2025-05-21(j)

To demonstrate “undue hardship,” an employer must establish that the “burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business.” Groff, 660 U.S. at 470.

Section 2000e(j)’s undue hardship analysis considers the cumulative impact of granting similar religious accommodation requests when there is no fair basis to distinguish among employees.

Jackson v. King County · filed 2025-07-18(j)

Finally, the Court agrees with defendants that, unless there is some articulable, fair basis to differentiate one employee’s request for an accommodation from another, one of the relevant factors that must be considered is the number of employees seeking the same accommodation and the cumulative impact granting those requests would have on the conduct of the employer’s business.

Section 2000e(j) excuses an employer from accommodating a religious practice when the available accommodations would impose undue hardship on its business.

North v. State of Washington · filed 2025-09-24(j)

Defendants have met their burden to show that potential accommodations available —allowing North to work remotely or continue working onsite unvaccinated—would have caused an undue hardship.

Section 2000e(j)'s undue hardship exception does not excuse a religious accommodation based on a speculative threat to federal funding.

Powerback Rehabilitation v. Kansas Dept. of Labor · filed 2025-09-26(j)

Powerback suggests compliance with state law places an undue hardship on it under Title VII. This is because Title VII permits an employer to deny a religious accommodation if doing so would result in an undue hardship on the employer. ... But as demonstrated above, a sincerity inquiry is not required under Title VII. Given this, the alleged threat to Powerback's federal funding source is specious. ... Thus, the hardship alleged by Powerback is effectively a nonissue.

Section 2000e(j) excuses an employer from a religious accommodation that would impose an undue hardship, including substantial health and safety risks to its operations.

Gamon · filed 2026-03-03(j)

Defendant has established that accommodating Plaintiff by allowing her to work in-person unvaccinated would have created a substantial increased cost and that Plaintiff could not have been accommodated with fully remote work in fall of 2021.

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

Berra · filed 2026-05-31(j)

For these reasons, the Court concludes that, on this record, there is no issue of material fact that accommodating Plaintiff—and hundreds of other unvaccinated coworkers—with N95 respirators and “regular testing” in lieu of vaccination would have imposed undue hardship under Title VII and Oregon law.

Section 2000e does not define what constitutes a Title VII “charge” filed with the EEOC.

Fisher v. Valley Stream Central High School District · filed 2025-08-27

Title VII does not define what constitutes a “charge.” See generally 42 U.S.C. § 2000e (Title VII “Definitions” section failing to define “charge”).

Section 2000e(k) covers lactation as a medical condition related to pregnancy.

Harris v. Cnn America, Inc / Warner Media Inc. · filed 2026-02-23(k)

And “lactation is a normal aspect of female physiology that is initiated by pregnancy and concludes sometime thereafter, and thus is a medical condition related to pregnancy” under this provision.

Section 2000e(k) covers lactation as a pregnancy-related medical condition, so disciplining or terminating an employee because she needs to pump breastmilk can constitute sex discrimination.

WEAVER · filed 2025-10-14(k)

As to discriminatory discipline and termination, Defendants concede that “[t]aking adverse actions based on [a] woman’s breastfeeding is prohibited by the [Pregnancy Discrimination Act (‘PDA’), 42 U.S.C. § 2000e(k)]”. (Docket No. 83 at 4 n.2) (quoting Hicks v. City of Tuscaloosa, 870 F.3d 1253, 1260 (11th Cir. 2017)). This prohibition follows from a straightforward application of pertinent statutory law. ... In the case sub judice, the Court held that “Defendants are not entitled to summary judgment on Plaintiff’s discriminatory discipline and termination claims” because “Plaintiff’s evidence suffices to create a triable issue as to whether [GAT’s] proffered reasons [for disciplining and terminating her] constitute a pretext for discrimination based on Plaintiff’s need to pump breastmilk”.

Section 2000e defines “person” to include governmental agencies, allowing Title VII employment-discrimination claims against state agencies.

Arkansas Highway Police, a Division of the Arkansas State Highway and Transportation Department v. Mays · filed 2026-04-09(a)

Unlike the above claims, an employment-discrimination claim under Title VII of the Civil Rights Act of 1964 may proceed against a state agency. 42 U.S.C. § 2000e. A “person” is defined to include “governmental agencies,” and it refers to discriminatory employment action by “employers.”

Section 2000e(b) includes states and their agencies among employers subject to Title VII suit.

Davis v. State University of New York · filed 1986-10-03(b)

We assume that because Magistrate Caden stated that he did not address the Title VII claims in his summary judgment order and because a state and its agencies have been subject to suit under Title VII since 1972 and have no Eleventh Amendment immunity, see Fitzpatrick v. Bitzer, 427 U.S. 445, 96 S.Ct. 2666, 49 L.Ed.2d 614 (1976); 42 U.S.C. Sec. 2000e(b) (1982), he did not intend to dismiss DMC as to the Title VII claims.

Section 2000e(b) includes government agencies in the definition of employer; a Title VII plaintiff suing state government must name the particular agency rather than the state.

Williams v. Doyle · filed 2007-05-31(b)

Even though Title VII defines “employer” to include both “governments” and “government agencies,” 42 U.S.C. § 2000e(b), the court of appeals has held with little discussion that plaintiffs suing state government under Title VII must name as a defendant the particular agency rather than the state.

Section 2000e includes state governments in its definition of “person” and state civil service workers in its definition of “employee,” allowing Title VII claims against state employers.

Jones v. Gee · filed 2020-02-05(a), (f)

Plaintiff has failed to meet the Ex Parte Young exception in this case, and as such, most claims against defendants LDH and Secretary Rebekah Gee should be dismissed, except for any Title VII claims levied against them.

Section 2000e’s definitions of employer, employment agency, and labor organization do not cover state bar examiners administering bar admission exams.

McFarland v. Folsom · filed 1994-03-18

The court held that: “Title VII does not apply by its terms, of course, because the Georgia Board of Bar Examiners is neither an “employer,” an “employment agency,” nor a “labor organization” within the meaning of the statute.” ... McFarland’s demands for relief under Title VII fail to state a claim upon which relief can be granted and are due to be dismissed, with prejudice.

Section 2000e(f)'s definition of “employee” includes former employees for retaliation claims involving future employment prospects or otherwise related to employment.

Veprinsky v. Fluor Daniel, Inc. · filed 1996-06-26(f)

Because neither section 704(a) nor the definition of "employee" expressly includes former employees, a literal reading of the statute would exclude them from coverage for acts of retaliation. ... We therefore conclude that former employees, in so far as they are complaining of retaliation that impinges on their future employment prospects or otherwise has a nexus to employment, do have the right to sue their former employers under section 704(a).

Section 2000e(b) defines an employer to include its agents; an official-capacity Title VII claim against an employee merges with the claim against the employer when both are sued.

Cooke-Seals v. District of Columbia · filed 1997-07-17(b)

Where the suit has been filed against the employer (here the District of Columbia) and one or more employees, however, the claims against the employees merge with the claim against the employer. ... The Title VII and ADA claims against the officers in their official capacities will be dismissed.

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

Momah v. Albert Einstein Medical Center · filed 1997-10-07(b)

Furthermore, to be held liable under Title VII an employer must have fifteen or more employees. 42 U.S.C. § 2000e(b). As the uncontradicted evidence here shows that plaintiff was never hired, fired or controlled by Old York Road Ob/ Gyn Associates and that this defendant never employed more than seven employees at a given time, summary judgment in favor of this defendant shall also be entered.

Section 2000e(b) excludes employers with fewer than fifteen employees from Title VII’s employment discrimination remedies.

Kerrigan v. Magnum Entertainment, Inc. · filed 1992-08-31(b)

The aforementioned cases can be distinguished from the case sub judice, however, because, this case involves a plaintiff who lacks alternative statutory remedies because her employer is exempted from Title VII and art. 49B.

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 year.

Samuels v. TARGET REALTY, LLC · filed 2021-10-13(b)

This total falls short of the fifteen employees required for a party to be deemed an “employer” under Title VII.