In its opinions, the court relied on previous decisions where it interpreted broad prohibitions of discrimination under similar civil rights statutes to include retaliation. By adhering to principles of stare decisis, the court found that the protection against retaliation was implicit in the text of the statutes.

In Humphries , the plaintiff, Hedrick G. Humphries, a former assistant manager of Cracker Barrel restaurant, claimed that his employer dismissed him because he complained to managers that another employee was discharged for race-based reasons. Humphries timely filed a complaint with the Equal Employment Opportunity Commission (EEOC) and received a “right to sue letter,” pursuant to federal law. He then filed a complaint in Federal District Court alleging, among other things, that Cracker Barrel’s actions violated 42 U.S.C. § 1981.

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