Employment Law-Title VII Does Not Extend to Third-Party Retaliation Claim by Fiancée of Discrimination Claimant-Thompson v. North American Stainless, LP , 567 F.3d 804 (6th Cir. 2009)

Section 704(a) of the Civil Rights Act of 1964 (Title VII) creates a cause of action for retaliation against claims of discrimination in the employment context.  To prevail in a Title VII retaliation claim, a plaintiff must prove that he or she engaged in Title VII protected activity, the defendant possessed knowledge of the protected activity, the defendant took an adverse employment action against the plaintiff, and a causal connection existed between the protected activity and the adverse employment action.  In Thompson v. North American Stainless, LP, the United States Court of Appeals for the Sixth Circuit (Sixth Circuit) considered whether section 704(a) extended to a thirdparty retaliation claim brought by the fiancée of a discrimination claimant.  The Sixth Circuit held that section 704(a) of Title VII does not create a cause of action for third-party retaliation claims where the claimant has not personally engaged in protected activity. . .