In Thompson v. North American Stainless, the Court held that third-party retaliation claims are permitted under Title VII of the Civil Rights act. In this action, Thompson's fiancé filed a sex discrimination charge against North American Stainless (NAS). After Thompson's fiancé filed the charge, NAS promptly fired Thompson.
In MARX v. GENERAL REVENUE CORP., 668 F. 3d 1174 (2013), the United States Supreme Court affirmed a decision that was upheld by the Tenth Circuit. The District Court had ordered the losing plaintiff, Marx (who had defaulted on her student loans) to pay the defendant's partial court and attorneys fees. In this case Marx had claimed that her creditor, General Revenue Corporation (GRC) was harassing her via phone calls and letters to her employer, and falsely claiming to garnish half of her wages. The decision, which was a matter of statutory interpretation, will help to provide other circuits with guidance, however, it has sparked an interesting policy concern.