Section 1981 relief here. B. The defendants claim that the district court’s grant of summary judgment in its favor on plaintiff Blasic’s claims for retaliation can be upheld on the alternate ground that Section 1981 does not contain an anti-retaliation provision. They argue that if we fail to apply Title VII employer exemptions to Section 1981, we must likewise decline to import an anti-retaliation principle from Title VII into Section 1981. This argument fails for two reasons. First, it was not raised in the district court. Second, it is foreclosed by Supreme Court and circuit precedent, which hold retaliation to be a form of differential treatment subsumed in the anti-discrimination language of Section 1981. Bryant v. Aiken Reg’l Med. Ctrs., Inc., 333 F.3d 536, 543 (4th Cir.2003) (<HOLDING>); see also Jackson v. Birmingham Bd. of Ed.,
holding that the mixedmotive framework does not apply to retaliation cases under title vii holding that a claim of retaliation for filing eeoc charges is cognizable under  1981 holding that a plaintiff can prove illegal retaliation under   1981 in the same manner as he establishes retaliation under title vii holding that retaliation claims are not cognizable under 42 usc  1981 holding that a plaintiff can sue for retaliation under title vi