The risk of employer liability for being tricked into taking an adverse employment action against an employee by a supervisor with discriminatory motives, i.e. cat’s paw liability, is real. On the heels of the U.S. Supreme Court’s March, 2011 decision in Staub v. Proctor Hospital, a number of lower courts have taken up the issue and found a basis for cat’s paw liability pursuant to various statutes. Additionally, since many states’ courts simply follow federal law when interpreting state civil rights laws, the cat’s paw legal theory is likely to find its way to purely state law cases as well as administrative agency investigations. This expansion of cat’s paw liability risk may require an expansion of HR compliance.