the multitude of cases that find a strong nexus between language and national origin. Although no court has explicitly held that language is a proxy for national origin, in the equal protection context, the Supreme Court has recognized that language may serve as an adjunct for an immutable characteristic: “It may well be, for certain ethnic groups and in some communities, that proficiency in a particular language, like skin color, should be treated as a surrogate for race under an equal protection analysis.” Hernandez v. New York, 500 U.S. 352, 371-72, 111 S.Ct. 1859, 114 L.Ed.2d 395 (1991). And, the Supreme Court and many lower courts have recognized the significant overlap and inherent correlation between language and national origin. See, e.g. Lau, 414 U.S. at 568-69, 94 S.Ct. 786 (<HOLDING>); Espinoza v. Fa-rah Mfg. Co., 414 U.S. 86,
holding that failure to provide educational assistance to nonenglishspeaking students constituted national origin discrimination under title vi holding that a plaintiff can sue for retaliation under title vi holding that texas twoyear statute of limitations applied to section 1981 action for discrimination on the basis of national origin holding that because the proper defendant in a title vi case is an entity rather than an individual plaintiff could not be sued in his individual capacity under title vi holding accent discrimination may be actionable as national origin discrimination under title vii citing with approval eeoc guidelines defining national origin discrimination to include discrimination based on the linguistic characteristics of a national origin group