Title VII Rights Extend Beyond Employer-Employee Relationship

After being terminated by her employer, IBP, Moland brought a Title VII action for sexual harassment and retaliation against Bil-Mar Foods. Moland claimed that Bil-Mar, while not her employer, had nonetheless interfered with her employment with IBP. The court, denying Bil-Mar's motion for summary judgment, found that "the rights created under Title VII extend beyond the immediate employer-employee relationship and apply to discrimination [and retaliation] claims . . . where the defendant is in a position to interfere with the plaintiff's employment opportunities even though the plaintiff is not an employee of the defendant.