Employment Litigation · Primary-source case analysis

Crawford: Answering Questions in an Internal Investigation Can Be Protected Opposition

By Aneeta Mishra and Timothy Chan

Published September 13, 2026

Crawford v. Metropolitan Government of Nashville interpreted Title VII’s opposition clause in the internal-investigation setting.

The employee answered an investigator’s questions

During an inquiry into another worker’s allegations, Vicky Crawford described sexually harassing conduct by the same supervisor.

Opposition includes resisting or speaking against misconduct

The ordinary meaning of oppose does not require an employee to start a complaint or use particular words.

The report was protected activity

Giving a disapproving account in response to questions could qualify as opposition to an unlawful practice.

The summary judgment was reversed

The Court resolved the protected-activity question and returned the case without deciding retaliation causation or the employer’s ultimate liability.

Key takeaways

• Treat internal-investigation participation as potentially protected.
• Document who asked each question and what was reported.
• Separate protected activity from causation and pretext.
• Avoid adverse action based on cooperation with an inquiry.