Maliszewska-Nienartowicz Justyna, Multiple Discrimination and the European Union - what Lessons Can Be Learnt from Canada and the US?

Discrimination is a social phenomenon and as such has been evolving, with new forms emerging and gaining importance. An interesting example in this respect is multiple discrimination, based on more than one ground. This contribution presents the definition and types of multiple discrimination as well as the ways of dealing with it in practice. The author first presents those jurisdictions which try to apply an intersectional approach to this form of discrimination, that is Canadian and US cases. Then the regulations of the EU as well as the case law of the Court of Justice are described. The conclusion contains a comparison between the EU approach on the one hand and those two national jurisdictions on the other. The author also tries to formulate some suggestions as to what the EU could do in future in order to strengthen protection against multiple discrimination.*