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Keywords

lawsuitplaintiffliabilityappealsummary judgmentdiscrimination

plaintiffwilldiscrimination

Related Cases

National R.R. Passenger Corp. v. Morgan, 536 U.S. 101, 122 S.Ct. 2061, 153 L.Ed.2d 106, 88 Fair Empl.Prac.Cas. (BNA) 1601, 82 Empl. Prac. Dec. P 41,042, 70 USLW 4495, 70 USLW 4524, 02 Cal. Daily Op. Serv. 5047, 2002 Daily Journal D.A.R. 6371, 15 Fla. L. Weekly Fed. S 347

Facts

Abner J. Morgan, Jr., a black male, filed a charge of discrimination and retaliation against Amtrak with the EEOC, alleging he was subjected to discriminatory acts and a racially hostile work environment during his employment. The EEOC issued a 'Notice of Right to Sue,' and Morgan subsequently filed a lawsuit. The District Court granted Amtrak partial summary judgment, ruling that only acts occurring within 300 days of the EEOC charge were actionable. Morgan appealed, leading to a reversal by the Ninth Circuit.

On February 27, 1995, Abner J. Morgan, Jr., a black male, filed a charge of discrimination and retaliation against Amtrak with the EEOC and cross-filed with the California Department of Fair Employment and Housing. Morgan alleged that during the time period that he worked for Amtrak he was 'consistently harassed and disciplined more harshly than other employees on account of his race.'

Issue

Whether a Title VII plaintiff can recover for acts of discrimination or retaliation that occurred outside the statutory filing period, specifically in the context of a hostile work environment claim.

We consider whether, and under what circumstances, a Title VII plaintiff may file suit on events that fall outside this statutory time period.

Rule

A Title VII plaintiff must file a charge within 180 or 300 days of the occurrence of discrete discriminatory or retaliatory acts, but a hostile work environment claim can include acts outside this period if at least one act occurred within the filing period.

A Title VII plaintiff raising claims of discrete discriminatory or retaliatory acts must file his charge within the appropriate 180– or 300–day period, but a charge alleging a hostile work environment will not be time barred if all acts constituting the claim are part of the same unlawful practice and at least one act falls within the filing period.

Analysis

The Court determined that discrete acts of discrimination are not actionable if they fall outside the statutory time period, as each act starts a new clock for filing. However, for hostile work environment claims, the Court ruled that the cumulative effect of all acts can be considered if at least one act contributing to the claim occurred within the filing period. This allows for a broader scope of evidence in assessing liability.

Conclusion

The Supreme Court affirmed in part and reversed in part the lower court's decision, allowing for the inclusion of acts outside the filing period in hostile work environment claims while maintaining strict adherence to the filing requirements for discrete acts.

Who won?

The Supreme Court's ruling was a partial victory for both parties; it affirmed the lower court's dismissal of discrete acts outside the filing period but allowed for the inclusion of prior acts in hostile work environment claims.

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