Thursday, May 24, 2012

Title VII retaliation must relate to EEOC charge

In Townsend v. Benjamin Enterprises, Inc., the 2d Circuit addressed an issue of first impression -- whether Title VII's "participation clause covers internal [i..e., employer] investigations not associated with a formal EEOC charge."  The court answered the question in the negtive, holding that Title VII's participation clause only extends to a formal EEOC investigation; "it does not include participating in an employer's internal, in-house investigation, conducted apart from a formal charge with the EEOC."


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