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Ruling that the so-called "manager rule" has no place in Title VII jurisprudence, the 4th Circuit reversed an order granting summary judgment to an employer who fired their employee for assisting a worker with a sexual harassment complaint.

The 4th Circuit Court of Appeals ruled that the employer's response to severe harassment (racist death threats) could be found by a reasonable jury to have been inadequate, where the employer is required to act promptly in a manner reasonably calculated to end the harassment.