Does Title VII Protect an Employee Who Participates in an Employer-Initiated Sexual Harassment Investigation?
The anti-retaliation provision (Section 704) of Title VII of the Civil Rights Act of 1964 (“Title VII”) prevents employers from discriminating against employees who have opposed any unlawful employment practice. This provision also protects employees who participate in the investigation of an unlawful employment practice. In Crawford v. Metro Gov’t of Nashville & Davidson County, 211 Fed. Appx. 373 (6th Cir. 2006), the Sixth Circuit determined that Section 704 of Title VII does not, however, protect employees who participate in an employer-initiated sexual harassment investigation. In mid-2002, Linda Crawford, a former employee of Metro Government of Nashville & Davidson County (“Metro”), was asked by Metro’s human resources department to participate in an investigation after claims were made by another employee that Metro school district’s employee relations director was sexually harassing female employees. Crawford explained that employee relations director had sexually harassed her
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