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Keywords

plaintiffdefendantstatuteappealmotionsummary judgmentdiscriminationclass actioncivil rightsstatute of limitations
lawsuitplaintiffdefendantprecedentsummary judgmentdiscriminationclass action

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Griffin v. Singletary

Facts

The case originated from a class action filed by Peners L. Griffin in 1979, alleging discrimination by the Florida Department of Corrections (FDOC) under Title VII of the Civil Rights Act. The district court initially certified a class of black employees but later vacated this certification based on a Supreme Court ruling. The court found that the named plaintiffs lacked standing to represent certain claims, leading to a series of appeals and motions regarding class certification and individual claims.

This lawsuit was filed in 1979 by Peners L. Griffin as an 'across-the-board' class action, under Fifth Circuit precedent that allowed a plaintiff who alleged pervasive discrimination to raise claims, on behalf of a class, that were different from his individual claims.

Issue

Whether the pendency of a Title VII class action tolls the administrative charge-filing period for class members when class certification is vacated due to the representative's failure to file a timely charge with the EEOC.

This case presents the question whether the pendency of a Title VII class action tolls the administrative charge-filing period for the class members when class certification is vacated because the representative failed to make a timely filing with the EEOC.

Rule

The court held that the pendency of a previously filed class action does not toll the limitations period for additional class actions by putative members of the original asserted class, but it does toll the statute of limitations for individual claims during the pendency of the first class action.

We hold that it does toll the period for those wishing to bring individual suits but does not for those wishing to bring class action suits.

Analysis

The court applied the rule by determining that while the class action's pendency does not allow for 'piggybacking' onto another class action, it does toll the charge-filing period for individual claims during the first class action's pendency. The court emphasized that the reliance on the class action's certification should discourage the proliferation of individual claims until a final determination is made.

Insofar as the individual claims are concerned, putative class members should be entitled to rely on a class action as long as it is pending.

Conclusion

The court affirmed the district court's rulings except for the summary judgment grant to the defendants regarding the individual claims of the putative class members, which it vacated and remanded for further proceedings.

The court affirmed all rulings except for the summary judgment grant to defendant correctional facilities in regards to plaintiff putative class members' individual claims, which the court vacated and remanded.

Who won?

The defendants prevailed on most issues, as the court upheld the district court's decisions regarding class certification and intervention, but the plaintiffs prevailed in part as the court vacated the summary judgment on individual claims.

The court affirmed the district court's decision to deny the intervention of certain people, reasoning that none of the potential intervenors filed a timely charge of discrimination with the Equal Employment Opportunity Commission.

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