Title VII of the Civil Rights Act of 1964 contains an anti-retaliation provision that makes it unlawful for an employer to retaliate against any employee who has opposed any unlawful practice covered by Title VII or has made a charge, testified, assisted, or participated in any manner in a Title VII investigation, proceeding, or hearing. In the U.S. Supreme Court's 2006 ruling in Burlington Northern & Santa Fe Railway Co. v. White, the Court held that Title VII's anti-retaliation provision may cover a “broad range” of employer conduct, such as some job reassignments and suspensions. In its 2009 ruling in Crawford v. Metropolitan Government of Nashville, the Supreme Court further expanded the scope of employer conduct covered by Title VII's anti-retaliation provision when it ruled that the provision protects an employee even when he or she has not filed a formal charge or complaint against the employer but instead refers to unlawful harassment during an investigation. Now, in its recent ruling in Thompson v. North American Stainless LP, the Supreme Court again has widened the range of employer conduct covered by Title VII's anti-retaliation provision by ruling that the provision prohibits an employer from taking any retaliatory adverse employment action that would deter an employee from engaging in activity protected by Title VII, even where the adverse action is directed at a worker other than the employee engaging in the protected activity. In Thompson, the Court held that an employee can pursue a claim against his employer under the anti-retaliation provision based on an allegation that he was fired because his fiancée, a co-worker, filed a gender discrimination claim against the company. Citing its decision in Burlington Northern that the main purpose of Title VII’s anti-retaliation provision is to protect workers from any employer action that could “dissuade a reasonable worker from making or supporting a charge of discrimination,” the Supreme Court in Thompson reasoned that the employee’s claim fell “within the zone of interests protected by Title VII.” The Court stated specifically that...