In the 2008 case of Vicky S. Crawford v. Metropolitan Government of Nashville and Davidson County, Tennessee, the U.S Supreme Court ruled in favor of Crawford who had been fired after reporting sexual harassment at work during an internal investigation into another employee's complaints. The court held that federal law protects employees from retaliation when they report discrimination or harassment internally, even if they do not file a formal complaint with authorities outside their workplace. This ruling clarified the scope of protection under Title VII of the Civil Rights Act which prohibits employers from retaliating against workers who oppose unlawful employment practices such as discrimination based on race, color, religion, sex or national origin.

The dissenting opinion in the case of Vicky S. Crawford v. Metropolitan Government of Nashville and Davidson County, Tennessee argued that the majority's interpretation of Title VII was too broad. The dissenters believed that an employee should not be protected from retaliation unless they have actively opposed unlawful practices or participated in investigations, proceedings, or hearings under Title VII. They contended that merely answering questions during an employer-initiated investigation does not constitute opposition to unlawful activity as defined by the statute. Therefore, according to this view, Crawford did not engage in any protected activity when she disclosed sexual harassment allegations during a company inquiry into another employee's behavior; thus her subsequent dismissal could not be considered retaliatory under Title VII.