United States Second Circuit

In a suit by an employee who claimed sexual harassment and a human resources director who was investigating the allegation: 1) summary judgment to the defendants on the human resources director's Title VII retaliation claim is affirmed, as participation in an internal employer investigation not connected with a formal EEOC proceeding does not qualify as protected activity under the participation clause; 2) there was no error in the district court's rulings on proxy or alter ego liability and individual liability; and 3) the attorney's fee award to a plaintiff is affirmed.

Appellate Information

• Decided 05/09/2012
• Published 05/09/2012

Judges

• John G. Koeltl

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Stephen Bergstein, Richard G. Kass