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| UNION LIABILITY UNDER TITLE VII BASED ON NUMBER OF MEMBERS |
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| A union member sued a Steelworkers' Local and his employer for a racially hostile work environment. The Local argued that it only had four employees, and therefore was not liable for compensatory damages. The Eighth Circuit found that the Local, which had over 1,500 members, should be treated like employers with 1,500 employees. |
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| (Dowd v. United Steelworkers of America, Local No. 286) |
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