Demasters v. Carilion Clinic: Elimination of the “Manager Rule” in Title VII Litigation
Jennifer MilakIntroduction In a recent case, Demasters, the United States Court of Appeals for the Fourth Circuit, determined the “manager rule,” which has its roots in Fair Labor Standards Act litigation, should not apply in Title VII litigation. Demasters v. Carilion Clinic, No. 13-2278, WL 4717873 (4th Cir. 2015). Under the rule, in order for an…