Employment Law Monthly - March 2012
Adverse Employment Actions Taken After Termination Can Lead To Liability Under Title VII
By Okechi C. Ogbuokiri
In a recent opinion, the Fourth Circuit Court of Appeals held that Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2 ("Title VII"), allows former employees to bring a claim against a former employer pursuant to this statute based, in part, on post-employment actions by the employer. This decision, Gerner v. County of Chesterfield, No. 11-1218 (4th Cir. Mar. 16, 2012), is consistent with other federal court decisions, which have asserted that former employees may bring claims regarding alleged discriminatory actions.