Most claims of employment discrimination under Title VII of the Civil Rights Act of 1964 (as amended) rely on circumstantial evidence. Title VII prohibits employment discrimination based on race, color, religion, sex and national origin.Title VII and Section 1981 prohibit employers from retaliating against employees because they have engaged in statutorily protected activity. Section 1981 grants individuals the right to make and enforce contracts, regardless of race. The general purposes of the Florida Civil Rights Act of 1992 are to secure for all individuals within the state freedom from discrimination. The First Circuit Court of Appeals held that there is no implied private right of action for damages against state actors under 42 USC Section 1981.