Netter v. Barnes, No. 18-1039 (4th Cir. 2018)Annotate this Case
The Fourth Circuit affirmed the district court's grant of summary judgment to the employer in an action alleging that the unauthorized review and disclosure of plaintiff's confidential personnel files to support her racial and religious discrimination claims constituted protected activity under Title VII.
The court held that, under the opposition clause, unauthorized disclosures of confidential information to third parties are generally unreasonable. In this case, plaintiff's unauthorized review and duplication of confidential personnel files did not constitute protected opposition or participation activity. The court also held that section 704(a) of Title VII of the Civil Rights Act does not protect a violation of valid state law that poses no conflict with Title VII. The court explained that, like in plaintiff's opposition claim, she failed to meet her burden of proving that the sheriff terminated her employment because she engaged in protected activity.