Rather, it is whether the speech was made pursuant to the employee's job duties, or in other words, whether it was 'commissioned' by the employer." Sexton v. City of Hannibal, 832 F. Supp. 2d 1060, 1065 (E.D. Mo. 2011) (quoting Garcetti, 547 U.S. at 421-22). The proper judicial inquiry is a "practical one," not controlled or limited by "[f]ormal job descriptions."

The law is well-established that "individual liability does not exist under Title VII." Sexton v. City of Hannibal, 832 F.Supp.2d 1060, 1066 (E.D. Mo. 2011); accord Powell v. Yellow Book USA, Inc., 445 F.3d 1074, 1079 (8th Cir. 2006); Nischan v. Stratosphere Quality, LLC, 865 F.3d 922, 930 (7th Cir. 2017); Littlejohn v. City of New York, 795 F.3d 297, 313 (2d Cir. 2015); Griffin v. Finkbeiner, 689 F.3d 584, 600 (6th Cir. 2012). Accordingly, Kirkman's Title VII claims against defendants—individuals in the employ of Faurecia—will be dismissed.