context: Addressing the Title VII claim, the Miller court recognized that the term "employer" includes the employer's "agent"; however, it agreed with the trial court that "the obvious purpose of this agent provision was to incorporate respondeat superior liability into the statute."
citation_a.signal: cf.
citation_a.identifier: 929 F.2d 220, 224
citation_a.parenthetical: employer liable for harassment by its employee under respondeat superior theory when it knew or should have known about harassment and failed to implement corrective action
citation_a.sentence: Id. at 587 (brackets omitted); see Sauers v. Salt Lake Co., 1 F.3d 1122, 1125 (10th Cir.1993) (when a plaintiff sues a supervisor under Title VII, the supervisor “operates as the alter ego of the employer, and the employer is liable for the unlawful employment practices”); cf. Bell v. Chesapeake & Ohio Ry. Co., 929 F.2d 220, 224 (6th Cir. 1991) (employer liable for harassment by its employee under respondeat superior theory when it knew or should have known about harassment and failed to implement corrective action).
citation_b.signal: see
citation_b.identifier: 1 F.3d 1122, 1125
citation_b.parenthetical: when a plaintiff sues a supervisor under Title VII, the supervisor "operates as the alter ego of the employer, and the employer is liable for the unlawful employment practices"
citation_b.sentence: Id. at 587 (brackets omitted); see Sauers v. Salt Lake Co., 1 F.3d 1122, 1125 (10th Cir.1993) (when a plaintiff sues a supervisor under Title VII, the supervisor “operates as the alter ego of the employer, and the employer is liable for the unlawful employment practices”); cf. Bell v. Chesapeake & Ohio Ry. Co., 929 F.2d 220, 224 (6th Cir. 1991) (employer liable for harassment by its employee under respondeat superior theory when it knew or should have known about harassment and failed to implement corrective action).