Crawford v. Metropolitan Government of Nashville & Davidson County


Respondent Metropolitan Government of Nashville & Davidson County undertook internal investigation of rumors of sexual harassment by the Metro School District employee relations director, Hughes. When a human resources officer asked Petitioner Crawford if she had witnessed any inappropriate behavior by Hughes, she cited three examples of his behavior toward her. Hughes was not disciplined but Crawford was fired.

Crawford sued under Title VII of the Civil Rights Act of 1964, which prohibits employers from retaliating against employees who report workplace discrimination.

The U.S. Supreme Court granted review to resolve a split in the circuits over whether Title VII protects an employee who does not initiate a complaint but merely responds to questions during an investigation.


An employee has a retaliation claim even though she merely addressed discrimination in response to an internal investigation. Because California statutory law already recognized retaliation claims on this basis, there should be no major impact in California.