Cheryl L. Feutz


Title VII of the Civil Rights Act of 19642 ("Title VII") prohibits employment discrimination Although no question exists that "employers" are liable for their discriminatory acts as well as for their agents' acts that occur within the scope of employment,4 a conflict exists among the federal circuits regarding whether Title VII's definition of "employer" also imposes individual liability upon the employer's agent. The Seventh Circuit answered this question for its circuit in Williams v. Banning.'

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