June 3, 2019 United States Supreme Court Decision Regarding EEOC's Charge of Discrimination



In the United State Supreme Court case, FORT BEND COUNTY, TEXAS v. DAVIS, the Court held that Title VII’s administrative-exhaustion requirement is not a jurisdictional prerequisite to a lawsuit, but is instead a waivable claim-processing rule.  

Title VII of the Civil Rights Act of 1964 – which forbids employers from discriminating against employees on the base of race, color, religion, sex and national origin – requires that an employee must first file a charge with the EEOC before going to court.

Fort Wayne Attorney Nathaniel Hubley
Fort Wayne Attorney Nathaniel Hubley
Monday’s decision stems from the case of Lois Davis, who says she was fired from her information-technology position with Fort Bend County, Texas, for attending a church event on a Sunday when she was scheduled to work. She also argued her supervisor retaliated against her for reporting sexual harassment by a co-worker, who resigned after an investigation.

Davis first filed a charge of harassment and retaliation with the EEOC in March 2011. While it was pending, she missed a work shift because of a previous commitment at church and was fired for that absence, according to court records.

She attempted to supplemental her EEOC charge by handwriting “religion” on one section of her questionnaire, but did not make any changes to the formal charge document.

Davis then received a notice of her right to sue from the Justice Department a few months later, and filed a federal lawsuit against Fort Bend County alleging religious discrimination and retaliation for reporting sexual harassment.  

A federal judge granted Fort Bend County summary judgment, but the Fifth Circuit reversed as to the religious discrimination claim. On remand, the county argued for the first time that Davis did not meet Title VII’s filing requirements by failing to state a claim based on religion in her EEOC charge.

The Fifth Circuit again reversed and the U.S. Supreme Court affirmed Monday, agreeing that Title VII’s administrative-exhaustion requirement is not a jurisdictional prerequisite to a lawsuit, but is instead a waivable claim-processing rule.  

The Court held that “a rule may be mandatory without being jurisdictional, and Title VII’s charge-filing requirement fits that bill.”

The Court held that an employee's failure to comply with steps outlined in Title VII does not always bar courts from exercising jurisdiction over the relevant claims, and that Fort Bend County waited too long to argue that Davis did not properly file her charge of religious discrimination.  

“A claim-processing rule may be ‘mandatory’ in the sense that a court must enforce the rule if a party ‘properly raise[s]’ it,” noted the Court. “But an objection based on a mandatory claim-processing rule may be forfeited ‘if the party asserting the rule waits too long to raise the point.’”


The Court further noted that, “Title VII’s charge-filing requirement is a processing rule, albeit a mandatory one, not a jurisdictional prescription delineating the adjudicatory authority of courts.”

The take away here is that in employment cases, employees need to be aware of the procedural requirements that govern their claims because failure to timely file something like a Charge of Discrimination with the EEOC could pose a bar to the employee's claim. It is always advisable to consult with an experienced employment law attorney.

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