I. INTRODUCTION
By recognizing a cause of action for third-party retaliation, the Supreme Court's decision in Thompson v. North American Stainless, LP1 repudiated the conclusions of four Circuit Courts of Appeals.2 Although a cause of action for third-party retaliation is a significant expansion of Title VII's retaliation protection, employers can minimize potential detrimental effects. Employers must recognize the scope of third-party retaliation protection and adopt appropriate responses to accommodate the new protection.
Part II of this Note traces the general history and purpose of Title VII, examines Title VII's statutory provisions, including the anti-retaliation …