This Note argues that the manager rule should be applied to Title VII cases but in a new and very specific and detailed context involving a case-by-case analysis, similar to that of the United States Court of Appeals for the Ninth Circuit’s reasoning in Rosenfield v. GlobalTranz Enterprises, Inc. This Note is comprised of three parts. Part I provides the history of Title VII generally, and discusses the emergence of the manager rule in the FLSA context. Part II addresses how different federal circuit courts have either recognized or rejected the manager rule as it applies to retaliation claims in the Title VII context. Part III discusses the benefits and drawbacks of the manager rule and proposes a solution that the manager rule should be applied to Title VII cases using a case-by-case analysis similar to that of the Ninth Circuit’s reasoning in Rosenfield.