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United States Fourth Circuit

DeMasters v. Carilion Clinic, 13-2278

In a former-employee's suit under Title VII of the Civil Rights Act of 1964, alleging that he was terminated for engaging in protected activity, including opposing an unlawful employment practice, the district court's dismissal of the complaint, on the grounds that no individual activity in which plaintiff engaged by itself constituted protected oppositional conduct and that the co-called "manager rule" prevented an employee whose job responsibilities included reporting discrimination claims from seeing protection under Title VII's anti-retaliation provision, is reversed where: 1) the proper test for analyzing oppositional conduct requires consideration of the employee's course of conduct as a whole; and 2) the "manager rule" has no place in Title VII jurisprudence.

Appellate Information

  • Decided 08/10/2015
  • Published 08/10/2015


  • Krause


  • United States Fourth Circuit


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