Until recently, managers have not been individually liable under Title VII, which protects employees against discrimination based on grounds such as race, color, religion, sex, or national origin. Liability is typically limited to the employer. A recent case from the Sixth Circuit (which covers Michigan, Tennessee, Kentucky and Ohio), however, has strayed from that general rule. 

In Mengelkamp v. Lake Metropolitan Housing Authority, a female plaintiff sued her employer and manager for sex discrimination. A jury found that her male manager consciously disregarded her rights and engaged in "outrageous" and "flagrant" actions. The jury awarded $105,000 in punitive damages against the manager. The Court of Appeals found that the manager held a supervisory position, had significant control over the plaintiff's firing, and was the person in charge of employment conditions. The manager was therefore an "employee" under the statute and could be found individually liable. Strict policies and training continue to be the best methods of preventing these types of claims.