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80 U. Chi. L. Rev. 1841 (2013)
Equal Opportunity: Federal Employees' Right to Sue on Title VII and Tort Claims

handle is hein.journals/uclr80 and id is 1865 raw text is: Equal Opportunity: Federal Employees' Right to Sue on Title VII and Tort Claims Kristin Sommers Czubkowskit INTRODUCTION For three years, Donald Rochon experienced a systematic campaign of racial discrimination and harassment from his coworkers that extended far beyond their mutual workplace. In addition to being subjected to racially discriminatory stories re- garding African Americans told by his coworkers, Rochon had his competence impugned behind his back, received hate mail and harassing phone calls, experienced assault and battery, and bore threats of death, mutilation, castration, and rape, among other abusive events.1 Had Rochon worked for a private employer, there is little question that he could recover under a Title VII employment discrimination claim as well as under several state tort causes of action. The Supreme Court affirmed the nonexclusivity of Title VII's remedies for private-sector employees in cases such as Al- exander v Gardner-Denver Co2 and Johnson v Railway Express Agency, Inc.3 In these cases, the Court recognized that the legis- lative history of Title VII manifests a congressional intent to al- low an individual to pursue independently his rights under both Title VII and other applicable state and federal statutes, and that the clear inference is that Title VII was designed to sup- plement, rather than supplant, existing laws and institutions re- lating to employment discrimination.4 However, because Donald Rochon worked for the Federal Bureau of Investigation, one of the first motions against him in his employment discrimination lawsuit was a motion to dismiss t BS 2008, University of Wisconsin; JD Candidate 2014, The University of Chicago Law School. 1 See Rochon v Federal Bureau of Investigation, 691 F Supp 1548, 1551-52 (DDC 1988). 2 415 US 36 (1974). 3 421 US 454 (1975). 4 Alexander, 415 US at 48-49. 1841

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