The Second Circuit held that the district court erred in granting Aramark summary judgment on King's Title VII hostile work environment claim. 5.1.7 Retaliation. 60.Last updated June 2024. Ellerth does not address the scope of either Title VII's general antidiscrimination provision or Title VII's antiretaliation provision. This PPP protects Federal employees and applicants for employment from retaliation when they exercise certain legal rights. Such allegations violate Title VII of the Civil Rights Act of 1964, which prohibits discrimination on the basis of sex. The US Supreme Court (SCOTUS) has clarified that employers must grant a religious accommodation request under Title VII of the Civil Rights Act of 1964.