GENERAL INTEREST we have received inquiries on this topic in the past, that this will be a “hot spot” of litigation in the months and years to come. All in all, we celebrate these new protections for Virginia’s workers and look forward to future lively debates with our defense bar colleagues. R Endnotes 1 No. 17–1618 (U.S. June 15, 2020). 2 Wrightson v. Pizza Hut of Am., Inc. , 99 F.3d 138 (4th Cir. 1996) (addresses LGBT rights vis-à-vis Title VII, as these individuals were collectively known then, in dicta); Murray v. N. Carolina Dep’t of Pub. Safety , 611 F. App’x 166 (4th Cir. 2015) (per curiam). 3 477 U.S. 57, 64 (1986). 4 523 U.S. 75 (1993). 5 Oncale , 523 U.S. at 80. 6 Hively v. Ivy Tech Cmty. College of Ind. , 853 F.3d 339 (7th Cir. 2017) (en banc); Zarda v. Altitude Express, Inc. , 883 F.3d 100, 132 (2d Cir. 2018) (en banc). 7 Proud v. Stone , 945 F.2d 796 (4th Cir. 1991). 8 Spencer v. Town of Bedford , 801 F. App’x 130 (4th Cir. 2020) (per curiam). 9 Compare Brief for Plaintiff, Spencer v. Town of Bedford (Case No. 6:18-cv-31; Docket No. 39) (detailing factual issues regarding plaintiff ’s treatment) with Spencer v. Town of Bedford , Case No. 6:18-cv-31, 2019 U.S. Dist. LEXIS 87358, 2019 WL 2305157 (W.D. Va. May 23, 2019) (finding factual issues described by plaintiff to be insufficient to overcome Proud inference). 10 See Va. Code Ann. § 2.2-3903 (repealed July 1, 2020). 11 Va. Code Ann. § 8.01-38.1. 12 A non-exhaustive list of other notable employment-related bills passed this Session include: 1. HB 123 & SB 838 – Private Right of Action for Nonpayment of Wages 2. HB 336 & SB 49 – Expanding DOLI Wage Theft Enforcement 3. HB 337 & SB 48 – Prohibiting Retaliation for Reporting Wage Theft 4. HB 30, Item 120 #1h – Adding More DOLI Enforcement Staff 5. HB 395 & SB 7 – Raising the Minimum Wage 6. SB 78 – Removing Exemption for Piece-Rate Workers 7. SB 804 – Removing Exemption for Domestic Workers 8. HB 1407 & SB 744 – Prohibiting Worker Misclassification and Empowering Department of Taxation to Investigate and Penalize Violations 13 9. HB 984 & SB 894 – Private Right of Action for Misclassified Workers 10. HB 1199 & SB 662 – Protection for Workers Who Report Misclassification 11. HB 1646 – Sanctions for Contractors Who Misclassify Workers 12. HB 56 – Prohibiting Misclassification of Tipped Workers 13. SB 868 (Virginia Values Act) – Adding a Private Right of Action to the Virginia Human Rights Act and Expanding Coverage 14. HB 827 & SB 712 – Prohibiting Pregnancy Discrimination 15. HB 1049 – Prohibiting Discrimination Based on Sexual Orientation and Gender Identity 16. HB 330 & SB 480 – Prohibiting Non-Compete Agreements for Low Wage Workers and Creating a Private Right of Action 17. HB 798 – Whistleblower Protection Law 18. HB 1201 & SB 380 – Permitting Localities to Impose Bidding Criteria for Contractors 19. HB 358 & SB 182 – Authorizing State and Local Authorities to Require Project Labor Agreements 20. HB 582 & SB 939 – Permitting Localities to Collectively Bargain with Public Employees 21. HB 833 & SB 8 – Requiring Prevailing Wages for Public Works Contracts 22. HB 1252 – Prohibiting Discrimination in Apprenticeship Programs 23. SB 548 – Addressing Unemployment Insurance Qualifications and Work-Sharing Program 24. SB 9 – Expands Occupational Disease Presumption for Workers’ Compensation 25. HB 46 – Requires Employer Notification of Intent to Accept or Deny Workers’ Compensation Claims 26. HB 55 – Establishing Worker Cooperatives as a Category of Cooperative Associations HB 123 & SB 838. After two federal clerkships and time practicing employ-ment defense at a large regional firm, L. Leigh R. Strelka joined forces with her spouse, Tommy Strelka, to form a boutique law firm focused on employee rights and quality of life for all attorneys/staff. When she is not wrangling Tommy, she is wrangling six-year old twins and practicing yoga. Winston West received his Bachelor of Science degree from the University of Richmond, before receiving his law degree from the Washington and Lee University School of Law. After law school, West joined Strelka Employment Law as an associate. West is particularly interested in the vindication of rights protected by Title VII, the Virginia Values Act, and Section 1983. Polly the office dog is a young Newfoundland who heads up Strelka Employment Law’s Canine Practice Group. She focuses on taking naps on the feet of our clients and providing them with calming emotional support when they visit the of-fice. She is also a very good girl. www.vsb.org GENERAL INTEREST FEATURES | VOL. 69 | AUGUST 2020 | VIRGINIA LAWYER 29