ROBINSON V SHELL-OIL-COMPANY - HAS THE SUPREME-COURT EXPANDED EMPLOYERS TITLE-VII LIABILITY

Title VII of the Civil Rights Act contains an anti-retaliation provisi on that prohibits an employer from discriminating against any of its e mployees or applicants for employment for engaging in protected activi ty under Title VII. In Robinson v. Shell Oil Company, the Supreme Cour t held ''employees'' under the anti-retaliation provision included for mer employees. Therefore, employees may now sue their former employers alleging retaliation under Title VII. Robinson will have an impact on future Title VII litigation. Courts will now be faced with the task o f determining what employer conduct is actionable under the anti-retal iation provision. While the scope of actionable employer conduct has y et to be defined, Robinson appears to have extended employer liability under Title VII well beyond the boundaries of the traditional employe r-employee relationship.