Skip to Search
Skip to Main Content
Main Content


News & Publications


Godfrey & Kahn Updates


Press Room


Summary of Legal Decisions: Post-Employment Claim of Retaliation Dismissed

Summer 1995

Bermudez v. Manpower, Inc., Civ. Action No. 94-C-649.

On June 23, 1995, John W. Reynolds, United States District Judge for the Eastern District of Wisconsin granted Manpower, Inc.'s Motion for Partial Dismissal, holding that a former employee may not bring a claim against his former employer for retaliation that allegedly occurred after the termination of the employment relationship. Mr. Bermudez resigned his employment with Manpower and subsequently became employed by TRC Holdings, Inc. He alleged that Manpower illegally retaliated against him when his former supervisor allegedly told his supervisor at TRC Holdings, Inc. that Mr. Bermudez had filed a charge of discrimination against Manpower.

Godfrey & Kahn, S.C., on behalf of Manpower, argued that, even if it occurred (which it did not), the alleged post-termination retaliation did not state a claim under Title VII of the Civil Rights Act of 1964. Judge Reynolds, accepting the position adopted by a minority of jurisdictions, agreed. The court also held that there was no actionable retaliation under 42 U.S.C. § 1981, which prohibits discrimination based on, among other things, national origin in the "... enjoyment of all benefits, privileges, terms and conditions of the contractual relationship." (emphasis in original).

Please wait while we gather your results.


Get practical insights on COVID-19 legal issues for your business.

Visit Resource Center

Media Contact 

If you have a media request or need an attorney with particular knowledge for comment, please contact Kyle Mondy, Marketing & Communications Manager, at 414.287.9481 or


Subscribe today to receive firm newsletters and blogs, client updates, seminar announcements, and more according to your preferences and areas of interest.


For more information on this topic, or to learn how Godfrey & Kahn can help, contact our COVID-19 Response Team.

Disclaimer and Legal Notices

Copyright © 2020 Godfrey & Kahn, S.C.

Attorneys at Law - All rights reserved.


Client Login