Mealey's (July 21, 2015, 4:57 PM EDT) -- RICHMOND, Va. — The Fourth Circuit U.S. Court of Appeals on July 15 reinstated a sexual harassment suit filed by a temporary factory employee, opining that Title VII of the Civil Rights Act of 1964 provides for joint employer liability and that when the “hybrid” test is properly applied to the worker’s suit, both the factory and the temp agency were the worker’s employers (Brenda Butler v. Drive Automotive Industries of America, Incorporated, et al., No. 14-1348, 4th Cir.; 2015 U.S. App. LEXIS 12188)....