Judge Edgardo Ramos
Williams is black. He worked for United States Information Systems (USIS) since 2000. From 2002 until resignation in May 2009, he was the only black employee working at USIS under Levine’s supervision. Arias Landscaping was a subcontractor for USIS. In addition to USIS, Williams sued Arias Landscaping, and owner Arias, for violating Title VII of the Civil Rights Act by constructively discharging him due to his race, and in retaliation for refusing to participate in their practice of having labor done by “undocumented aliens or illegal workers.” The court dismissed suit as against Arias. Arias could not be held liable under Title VII because he was never Williams’ employer or supervisor. Title VII’s protections extend only to employment relationships, and no such relationship existed between Williams and Arias. Further, because circuit law establishes that individuals are not subject to liability under Title VII, Arias could not be held liable even if he was a USIS employee and supervised Williams’ work. Given Williams’ concession that he supervised the workers supplied by Arias, the individuals supplied by Arias Landscaping, illegal or not, were no more than “mere co-workers” whose actions could not form the basis of a Title VII violation.
