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Vaughn v. Lawrenceburg Power System

United States Court of Appeals for the Sixth Circuit

293 F.3d 703 (2001)

Relevant factsFree

Lawrenceburg Power System (LPS) (defendant), a Tennessee state utility, maintained an anti-nepotism policy requiring one of two coworkers who marry each other to resign; Keith and Jennifer Vaughn (plaintiffs), both LPS employees, were reminded of the policy upon their engagement and told one would need to resign before marrying, though they could both keep working if they remained unmarried. Wanting to marry because Jennifer was pregnant, they married in January 1998 without either resigning, prompting LPS to suspend both pending a decision on who would resign; Keith told LPS Jennifer would resign, but she neither returned to work nor submitted a resignation letter, and LPS fired Keith. The Vaughns sued under § 1983, and Keith separately sued under the Tennessee Human Rights Act (THRA); the trial court's ruling was appealed.

IssueFree

Whether a government employer's anti-nepotism policy is constitutional where it requires the resignation of an employee who marries a coworker.

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