Under Title VII of the Civil Rights Act of 1964, a plaintiff shall file an employment discrimination charge with the Equal Employment Opportunity Commission (EEOC) either 180 or 300 days after an alleged unlawful employment practice occurred. Abner Morgan filed a charge of discrimination and retaliation with the EEOC against National Railroad Passenger Corporation (Amtrak), alleging that he had been subjected to discrete discriminatory and retaliatory acts and had experienced a racially hostile work environment throughout his employment. The EEOC issued a "Notice of Right to Sue." While some of the allegedly discriminatory acts occurred within 300 days of the time that Morgan filed his EEOC charge, many took place prior to that period. The District Court granted Amtrak summary judgment in part, holding that the company could not be liable for conduct occurring outside of the 300-day filing period. In reversing, the Court of Appeals held that a plaintiff may sue on claims that would ordinarily be time-barred so long as they either are sufficiently related to incidents that fall within the statutory period or are part of a systematic policy or practice of discrimination that took place, at least in part, within the period.
May a plaintiff, under Title VII of the Civil Rights Act of 1964, sue on employment discrimination claims that fall outside the statute's 300-day limit? May a plaintiff sue on claims that fall outside the period so long as the claims contribute to claims that took place within the period?
No and yes. In an opinion delivered by Justice Clarence Thomas, the Court held that Title VII of the Civil Rights Act of 1964 precludes recovery for discrete acts of discrimination or retaliation that occur outside the statutory time period. The Court also held that consideration of the entire scope of a hostile work environment claim, including behavior alleged outside the statutory time period, is permissible for the purposes of assessing liability, so long as any act contributing to that hostile environment takes place within the statutory time period. Justice Thomas wrote that the Court's holding does not leave employers defenseless when a plaintiff unreasonably delays filing a charge, noting that the application of equitable doctrines may either limit or toll the time period within which an employee must file a charge.
Decisions
Decision: 5 votes for Morgan, 4 vote(s) against Legal provision: Civil Rights Act of 1964, Title VII
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Full Opinion by Justice Clarence Thomas
