Sixth Circuit recognizes that members of protected class, and their associates, are protected by Title VII
In Barrett v. Whirlpool, the Sixth Circuit held that Title VII protects not only the members of a class who had previously been discriminated against, but also the close associates of members of the class. The Plaintiffs were caucasian employees of Whirlpool Corporation who alleged that they had suffered discrimination, retaliation or a hostile work environment as a result of their association with, and advocacy for, African-Americans. The trial court had dismissed their claims, holding that since they were not members of the protected class, Title VII did not apply to them. The Sixth Circuit held that federal law barred discrimination against these non-members of the protected class, as well as the members, and returned the case to the trial court to allow the plaintiffs an opportunity to prove their claims.