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Crawford v. Metropolitan Government of Nashville and Davidson County, Tennessee (06-1595) 
Whether Title VII protects employee from retaliation for cooperating with employer's internal investigation 





Crawford claimed she was discharged because she cooperated in her employer's investigation of sexual harassment complaints against another employee. No EEOC charge had been filed prior to the investigation. 

Title VII Section 704(a) protects an employee from retaliation because the employee "has opposed" an unlawful employment practice or "participated in any manner in an investigation ... under this chapter." The 6th Circuit held that Crawford was not protected by either the "opposition" clause or the "participation" clause. 

Case below:  Crawford v. Metropolitan Government of Nashville and Davidson County, Tennessee (6th Cir 11/14/2006) (unpublished) 
Official docket sheet 
Oral argument:  October 6, 2008.  [The Solicitor General participates in oral argument as amicus curiae in support of Petitioner.]
Certiorari granted January 18, 2008  

Question presented:  

Does the anti-retaliation provision of section 704(a) of Title VII of the 1964 Civil Rights Act protect a worker from being dismissed because she cooperated with her employer’s internal investigation of sexual harassment? 

Certiorari Documents: 

Briefs on the merits: 

Counsel:

  • For Petitioner Vicky S. Crawford: Ann Buntin Steiner; Steiner & Steiner; 214 Second Avenue, N., Suite 203; Nashville, TN  37201-1644; (615)-244-5063. 
  • For Respondent Metropolitan Government of Nashville and Davidson County, Tennessee: Francis H. Young; Metropolitan Government of Nashville and Davidson County; P.O. Box 196300; Nashville, TN  37219; (615) 862-6341. 

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