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."