Case law under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), and the Age Discrimination in Employment Act (ADEA), generally holds individuals cannot be found liable.

Unfortunately, the clear language in case law supporting the dismissal of individuals has not prevented plaintiffs from bringing claims under these statutes. For example, a federal court judge in Oregon recently outlined this costly and questionable practice in his opinion in a case involving Starbucks, stating: