Title VII Race Discrimination Claims Apply to Discriminatory Conduct Based on an Employees Association with a Person of Another Race
On April 1, 2008, the United States Court of Appeals for the Second Circuit ruled for the first time that an employer can be held liable for race discrimination based on an employee’s association with a person of another race. The court reversed the District Court’s decision to grant Defendant Iona College’s motion for summary judgment, rejecting the District Court’s restrictive view of Title VII race claims as applying only to an individual “because of such individual’s race.” Instead, the court found that where the Plaintiff-employee, Craig Holcomb, a white man, was allegedly terminated and discriminated against because of his marriage to an African-American woman, “the employee suffers discrimination because of the employee’s own race.”
Plaintiff, an assistant basketball coach at Iona College, alleged that he was terminated based on his supervisors’ discriminatory animus against his interracial marriage. The court found that the plaintiff had adduced enough evidence, through the comments and conduct of his supervisors, to show that his termination was based, at least in part, on improper racial motives. The Court noted that even though Iona College had proffered valid reasons for Holcomb’s termination, namely the poor performance of Iona’s basketball team, the employee need only show that “the prohibited factor was at least one of the ‘motivating’ factors” in his termination.
This ruling may also open the door to other claims of discrimination based on association, such as religious discrimination based on an employees association with a person of another religion.
