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Non-Employees

Fisher Phillips

Snapshot for Construction Employers: Courts Split on Liability Standard for Harassment Claims Based on Non-Employee Conduct

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In this edition of FP Snapshot for Construction Employers, we’ll cover the industry’s heightened risk of harassment claims based on the conduct of a non-employee (such as a subcontractor, inspector, vendor, or any other third...more

Fisher Phillips

Snapshot for Hospitality Employers: Appeals Courts Split on Liability Standard for Workplace Harassment by Non-Employees

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Welcome to this edition of FP Snapshot for Hospitality Employers, where we take a quick snapshot look at a recent significant workplace law development with an emphasis on how it impacts employers in the hospitality industry....more

Fisher Phillips

Snapshot for Manufacturers: Appeals Courts Split on Liability Standard for Workplace Harassment by Non-Employees

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Welcome to this edition of FP Snapshot for Manufacturers, where we take a quick snapshot look at a recent significant workplace law development with an emphasis on how it impacts employers in the manufacturing sector. This...more

Venable LLP

The Customer Isn’t Always Right: Employer Liability for Third-Party Harassment

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Picture this: It’s late Friday evening and you are almost packed up for the weekend when your human resources manager knocks on your office door. Judging by the look on his face, you two aren’t going home just yet. He...more

Frantz Ward LLP

Sixth Circuit Introduces Higher Standard Regarding Harassment by Non-Employees

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In August, the Sixth Circuit departed from EEOC guidance and other Circuits’ case law in ruling that an employer can only be held liable under Title VII for a non-employee’s harassment if the employer intended for the...more

Fisher Phillips

Appeals Court Limits Title VII Liability for Non-Employee Conduct: Key Takeaways for Employers

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Can an employer be held liable for workplace harassment committed by a non-employee? The short answer is “sometimes” – but a federal appeals court just significantly narrowed this liability risk for employers in Kentucky,...more

Ius Laboris

South Korea’s ‘Yellow Envelope Act’ Enhances Union Protection

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South Korea’s so-called ‘Yellow Envelope Act’ has been passed, strengthening protections for union activities within an already supportive legal framework. We summarise the key provisions and takeaways for employers....more

Foley & Lardner LLP

Employer Liability for Non-Employee Acts? Sixth Circuit Imposes High Standard and Rejects EEOC Guidance

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With its August 8, 2025, opinion in Bivens v. Zep, Inc., the U.S. Court of Appeals for the Sixth Circuit rejected the EEOC’s guidelines (and split with several other circuits) to hold that the standard for holding an employer...more

Vedder Price

Sixth Circuit Splits with EEOC and Other Circuits as to Employer Liability for Harassment by Non-Employees Under Title VII

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In Bivens v. Zep, Inc., No. 24-2109 (6th Cir. Aug. 8, 2025), the Sixth Circuit split with the EEOC and most U.S. Courts of Appeals as to when an employer may be liable under Title VII for harassment by a non-agent (e.g.,...more

Bradley Arant Boult Cummings LLP

If You See Something, Do You Fix It If It Isn’t Your Employee? 6th Circuit Applies Higher Standard to Non-Employee Harassment Case

An employee tells you a customer just harassed them — what should you do? In Bivens v. Zep, Inc. the Sixth Circuit Court of Appeals charts its own course in addressing employer liability for third-party harassment. The Equal...more

Littler

Sixth Circuit Limits Employer Liability for Harassment by Nonemployees

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On August 8, 2025, the U.S. Court of Appeals for the Sixth Circuit ruled an employer is not liable for harassment of an employee by a third party unless the employer intended for the harassment to occur. This stark departure...more

Benesch

Sixth Circuit Raises Standard for Employer Liability in Customer Harassment Cases

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When is an employer liable for the harassment of an employee by a non-employee? The Sixth Circuit answered this question on Friday in Bivens v. Zep, Inc., holding that Title VII imposes liability for customer (or other...more

Phelps Dunbar

Sixth Circuit Redefines Employer Liability for Client-Based Harassment

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In an explicit departure from EEOC guidance and other federal court caselaw, the United States Court of Appeals for the Sixth Circuit recently held that an employer can only be liable for a client/customer’s harassment of its...more

Bradley Arant Boult Cummings LLP

No. 1 of 10 Things Every Employer Should Know About OSHA: Walkaround Representatives

Please follow along as we discuss the top 10 things every employer should know about OSHA over the next few weeks. 1. Employers and employees have the right to have a company employee or non-employee representative...more

Spilman Thomas & Battle, PLLC

The Site Report - Construction Industry Insights, Issue 5, May 2024

Welcome to our fifth issue of 2024 for our construction industry insights e-newsletter - The Site Report. In our Ask the Attorney segment at the bottom of this e-newsletter, we tap Jonathan Deasy, Senior Attorney in our...more

Sheppard Mullin Richter & Hampton LLP

OSHA Issues Final Rule Clarifying an Employee’s Ability to Have a Non-Employee Representative Present During Inspection

On April 1, 2024, the U.S. Department of Labor’s Occupational Safety and Health Administration (“OSHA”) published its Final Rule clarifying the rights of employees to designate a non-employee representative to be present...more

Bradley Arant Boult Cummings LLP

OSHA Rights: You Have the Right to Retain a Representative

The Occupational Safety and Health Administration (OSHA) has published a final rule amending a regulation regarding the right to designate a representative to accompany OSHA inspectors during a workplace inspection. Why do we...more

Bass, Berry & Sims PLC

Can a Non-Employee Join a Safety Inspection? Yes, Under OSHA’s New Worker Walkaround Rule a Non-Employee Can Serve As an Employee...

On April 1, the Occupational Safety and Health Administration (OSHA) published its Worker Walkaround Representative Designation Process Rule, which is set to take effect 30 days after its publication in the Federal Register...more

Steptoe & Johnson PLLC

OSHA Final Rule Permits a Non-Employee to Attend an OSHA Inspection

The highly anticipated “walkaround” rule on clarifying rights to employee representation in Occupational Safety and Health Administration (OSHA) inspections has now been issued. It was published on Friday, March 29, and will...more

Seyfarth Shaw LLP

Union Intrusion: New OSHA Rule Permits Non-Employee Union Representatives on OSHA Inspection Walkarounds

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On April 1, 2024, the Federal Register published OSHA’s final rule revising its regulations regarding whom employees can authorize to act as their representative(s) to accompany compliance officers during on-site OSHA...more

Stark & Stark

Recent NJ Appellate Division Offers Guidance on Sexual Harassment of Non-Employees

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The New Jersey Appellate Division issued a decision which sheds light on the issue of whether an employee’s sexual harassment of a third-party (non-employee) could subject the employer to liability under the New Jersey Law...more

Steptoe & Johnson PLLC

There’s No Concerted Action If It’s Just One Employee or If It’s for a Non-Employee, Right? WRONG, Says the NLRB

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In two opinions released on August 31, the National Labor Relations Board (NLRB) overruled two 2019 decisions to expand the scope of workers’ concerted activity protections under the National Labor Relations Act (NLRA). Those...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OSHA Proposes Rule to Allow Third Parties to Participate in Workplace Walkaround Inspections

On August 30, 2023, the Occupational Safety and Health Administration (OSHA) published a proposed rule that would change the scope of who would be allowed to participate in walkarounds conducted as part of OSHA inspections. ...more

Steptoe & Johnson PLLC

NLRB Issues Complaint for Athlete Misclassification against NCAA, Pac-12, and USC

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On May 18, 2023, the National Labor Relations Board’s (the Board) regional director in Region 31 issued a complaint against the National Collegiate Athletic Association (NCAA), the Pac-12 Conference, and the University of...more

Proskauer - Labor Relations Update

UPDATE: NLRB Regional Director Issues Complaint Against USC, Pac-12, and the NCAA

On May 18, 2023, Region 31 of the National Labor Relations Board (“Board”) issued an unfair labor-practice complaint against USC, the PAC-12, and the NCAA for allegedly misclassifying college athletes as non-employees and...more

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