District Court Holds that Lack of Extraterritorial Application of Title VI Warrants Dismissal Even Though Certain Non-U.S. Employees Were Alleged to Have “Worked” in the U.S. Electronically, Via the Internet and by Telephone

The World in U.S. Courts: Summer 2014 - Employment Discrimination

Davenport v. HansaWorld USA, Inc., U.S. District Court for the Southern District of Mississippi, June 30, 2014

Plaintiff Davenport sued her employer for discrimination under Title VI of the Civil Rights Act of 1964. Her complaint was dismissed as to one defendant on grounds that it employed an insufficient number of employees in the U.S. to be subject to the statute. On a motion for reconsideration, the Court rejected Davenport’s argument that 45 employees working outside the U.S. should be deemed to be working in the U.S. for purposes of Title VII because of the extent of their communication with the U.S. via the Internet, telephone, and the U.S. Mail.

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