It is common knowledge that Title VII of the Civil Rights Act of 1964 (Title VII) prohibits employment discrimination on the basis of an employee's protected characteristic, such as race, color, religion, sex and national origin. What remained unsettled law in the U.S. Court of Appeals for the Third Circuit (encompassing Pennsylvania, New Jersey and Delaware) until this summer was whether Title VII prohibited action taken against an employee because of that employee's association with someone of a different protected characteristic.