Crawford v. Metropolitan Government of Nashville and Davidson County, Tennessee

Summary

The Supreme Court held that Title VII's antiretaliation provision, 42 U.S.C. § 2000e-3(a), protects an employee who reports discrimination not on her own initiative but in answering questions during an employer's internal investigation, because 'oppose' carries its ordinary meaning of resisting or contending against and is not limited to active, consistent, self-initiated complaint. The Court reasoned that the Sixth Circuit's narrower rule would undermine the Ellerth/Faragher framework that induces employers to investigate harassment and would deter employees from reporting Title VII violations. Because Crawford's conduct was covered by the opposition clause, the Court did not reach her participation-clause argument, and Metro's other summary-judgment defenses remain open on remand; the Sixth Circuit's judgment was reversed and remanded. Justice Alito, concurring in the judgment and joined by Justice Thomas, agreed with the result and the Court's primary reasoning but emphasized that the holding should not extend beyond purposive conduct such as testifying in internal investigations, questioning whether silent opposition is covered.