## Facts

- Mary Gossman Ruedlinger previously filed an EEOC discrimination charge against her employer, Robert L. Jarrett (Jarrett Management Company).
- The EEOC matter was resolved through a predetermination settlement agreement requiring both parties to keep matters relating to the charge confidential.
- After Ruedlinger’s employment ended, she obtained a job with a different employer.
- Ruedlinger alleged Jarrett contacted her new employer and disclosed confidential settlement-related information.
- She alleged the disclosure caused her termination from the subsequent job.
- Ruedlinger sued under Title VII’s anti-retaliation provision, alleging (i) retaliation based on the post-employment disclosure and (ii) that Jarrett’s breach of the settlement agreement constituted actionable retaliation.

## Issues

1. Whether Title VII’s anti-retaliation provision, 42 U.S.C. § 2000e-3(a), can reach retaliatory acts by a former employer occurring after the employment relationship ends.
2. Whether an alleged breach of an EEOC predetermination settlement agreement (through disclosure of confidential charge-related information to a subsequent employer) can support a Title VII retaliation claim.

## Decision

- The Seventh Circuit reversed the district court’s Rule 12(b)(6) dismissal and remanded.
- Applying intervening circuit precedent, the court held post-employment conduct may be actionable retaliation where it arises out of or relates to the prior employment relationship and the plaintiff’s protected activity.
- The court concluded the complaint adequately alleged retaliation: Jarrett’s alleged disclosure of confidential EEOC-settlement information to a subsequent employer, allegedly causing termination, could constitute adverse retaliatory conduct.
- The court treated the alleged settlement-agreement breach not as an independent contract claim in this action, but as alleged retaliatory conduct supporting liability under § 2000e-3(a).

## Legal Principles

- Under 42 U.S.C. § 2000e-3(a), retaliation claims may be based on certain post-employment actions by a former employer when the conduct is related to the prior employment relationship and to protected Title VII activity.
- Interference with a former employee’s future employment prospects, if done because of protected activity, can qualify as actionable retaliation.
- On a Rule 12(b)(6) motion, the court accepts well-pleaded factual allegations as true and asks whether they state a plausible claim for relief under the governing legal standard.

## Conclusion

The Seventh Circuit held that Title VII’s retaliation provision can cover post-employment retaliatory acts tied to the former employment relationship and protected activity, and that allegations of using confidential EEOC settlement information to harm subsequent employment stated a claim sufficient to survive dismissal.


Ruedlinger v. Jarrett, 106 F.3d 212 (7th Cir. 1997)