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Keywords

jurisdictionappealmotioncivil rightsrespondentmotion to dismiss
jurisdictionappealmotioncivil rightsrespondentmotion to dismiss

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Metropolitan Enterprises, Inc.; U.S. v.

Facts

Petitioner Darlene Walters was employed by respondent Metropolitan Educational Enterprises, Inc., a retail distributor of encyclopedias, dictionaries, and other educational materials. In 1990, she filed a charge with the Equal Employment Opportunity Commission (EEOC), claiming that Metropolitan had discriminated against her on account of her sex in failing to promote her to the position of credit manager. Soon after that, Metropolitan fired her. On April 7, 1993, petitioner EEOC filed suit against Metropolitan and its owner, respondent Leonard Bieber, alleging that the firing constituted unlawful retaliation. Walters intervened in the suit. Metropolitan filed a motion to dismiss for lack of subject-matter jurisdiction, claiming that the company did not pass the 15-employee threshold for coverage under Title VII.

Petitioner Darlene Walters was employed by respondent Metropolitan Educational Enterprises, Inc., a retail distributor of encyclopedias, dictionaries, and other educational materials. In 1990, she filed a charge with the Equal Employment Opportunity Commission (EEOC), claiming that Metropolitan had discriminated against her on account of her sex in failing to promote her to the position of credit manager. Soon after that, Metropolitan fired her. On April 7, 1993, petitioner EEOC filed suit against Metropolitan and its owner, respondent Leonard Bieber, alleging that the firing constituted unlawful retaliation. Walters intervened in the suit. Metropolitan filed a motion to dismiss for lack of subject-matter jurisdiction, claiming that the company did not pass the 15-employee threshold for coverage under Title VII.

Issue

The main legal issue was whether an employer 'has' an employee on any working day on which the employer maintains an employment relationship with the employee, or only on working days on which the employee is actually receiving compensation from the employer.

The main legal issue was whether an employer 'has' an employee on any working day on which the employer maintains an employment relationship with the employee, or only on working days on which the employee is actually receiving compensation from the employer.

Rule

Title VII of the Civil Rights Act of 1964 applies to any employer who 'has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.'

Title VII of the Civil Rights Act of 1964 applies to any employer who 'has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.'

Analysis

The court held that the payroll method represents the fair reading of the statutory language, which sets as the criterion the number of employees that the employer 'has' for each working day. The court emphasized that in common parlance, an employer 'has' an employee if he maintains an employment relationship with that individual, regardless of whether the employee is receiving compensation on that day.

The court held that the payroll method represents the fair reading of the statutory language, which sets as the criterion the number of employees that the employer 'has' for each working day. The court emphasized that in common parlance, an employer 'has' an employee if he maintains an employment relationship with that individual, regardless of whether the employee is receiving compensation on that day.

Conclusion

The judgment of the court of appeals granting the employer's motion to dismiss was reversed.

The judgment of the court of appeals granting the employer's motion to dismiss was reversed.

Who won?

The petitioner, Darlene Walters, prevailed in the case because the court found that the employer's interpretation of the employee count was incorrect and that the payroll method should be used to determine the number of employees.

The petitioner, Darlene Walters, prevailed in the case because the court found that the employer's interpretation of the employee count was incorrect and that the payroll method should be used to determine the number of employees.

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