Workplace discrimination based on an employee's "association" with another
individual, who comes within a protected classification (e.g., sex, race, religion)
or who has engaged in protected activity (e.g., whistle-blowing). In
Holcomb v. Iona Coll., 521 F.2d 130 (2d Cir.
2008), a Caucasian former assistant basketball coach alleged that he
was terminated because his spouse was African-American. The U.S. Court of Appeals
in New York agreed that this allegation was sufficient to state a claim of "associational"
discrimination under Title VII of the Civil Rights Act of 1964. The court stated:
"Where an employee is subjected to adverse action because an employer disapproves
of interracial association, the employee suffers discrimination because of the
employee's own race."
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