The U.S. Supreme Court handed down its decision in Fort Bend County v. Davis, a case which addresses whether Title VII’s administrative-exhaustion requirement is a jurisdictional prerequisite in a discrimination lawsuit.
In the Fort Bend County case, Lois Davis filed an Equal Employment Opportunity Commission (EEOC) charge against her employer, petitioner Fort Bend County, alleging sexual harassment and retaliation. Davis later attempted to supplement her EEOC charge by handwriting “religion” on a form called an “intake questionnaire,” but she did not amend the formal charge document. After years of litigation in federal court, only the religion-based discrimination claim remained in the case. Fort Bend then asserted for the first time that the District Court lacked jurisdiction to adjudicate Davis’ case because her EEOC charge did not state a religion-based discrimination claim. The District Court agreed and granted Fort Bend’s motion to dismiss Davis’ suit. On appeal from the dismissal, the Court of Appeals for the Fifth Circuit reversed. Title VII’s charge-filing requirement, the Court of Appeals held, is not jurisdictional. The Supreme Court affirmed the Fifth Circuit’s ruling.
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