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Fort Bend County, Texas v. Davis

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Supreme Court of the United States
Fort Bend County, Texas v. Davis
Term: 2018
Important Dates
Argument: April 22, 2019
Decided: June 3, 2019
Outcome
Affirmed
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh


Fort Bend County, Texas v. Davis is a case argued before the Supreme Court of the United States on April 22, 2019, during the court's 2018-2019 term. The case concerned whether federal courts have the authority to hear Title VII employment discrimination claims if the plaintiff has not completed an administrative process required under Title VII of the Civil Rights Act of 1964.

On June 3, 2019, the court affirmed the ruling of the United States Court of Appeals for the 5th Circuit, holding a federal court can hear claims under Title VII of the Civil Rights Act of 1964 even if the plaintiff has not completed an administrative process required under Title VII.[1] Click here for more information on the opinion.

The case came on a writ of certiorari to the 5th Circuit.[2]

HIGHLIGHTS
  • The case: Lois Davis, an IT supervisor for Fort Bend County, Texas, sued Fort Bend County in federal district court, alleging retaliation and religious discrimination under Title VII of the Civil Rights Act of 1964. After several appeals, the 5th Circuit reversed the district court's ruling dismissing Davis' claim. In its reversal, the 5th Circuit ruled that a federal court could hear Title VII claims even if the plaintiff had not completed an administrative process required under Title VII. The ruling was consistent with holdings from seven other circuits and inconsistent with rulings from three circuits.
  • The issue: "Whether Title VII's administrative exhaustion requirement is a jurisdictional prerequisite to suit, as three Circuits have held, or a waivable claim-processing rule, as eight Circuits have held."[3]
  • The outcome: The court affirmed the 5th Circuit's ruling, holding a federal court can hear claims under Title VII of the Civil Rights Act of 1964 even if the plaintiff has not completed an administrative process required under Title VII.[1]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • June 3, 2019: U.S. Supreme Court affirmed the 5th Circuit's ruling.
    • April 22, 2019: Oral argument
    • January 11, 2019: U.S. Supreme Court agreed to hear the case
    • October 18, 2018: Petition filed with U.S. Supreme Court
    • June 20, 2018: 5th Circuit reversed a federal district court's ruling

    Background

    Lois Davis was an information technology (IT) supervisor for Fort Bend County, Texas. In 2010, Davis filed a complaint with the county human resources department accusing the IT director of sexual harassment and assault. After a county investigation found evidence supporting Davis' claim, the director resigned. According to Davis, her supervisor, who was a personal friend of the IT director, began retaliating against her for filing the complaint. Davis then filed a charge with the Texas Workforce Commission alleging sexual harassment and retaliation.[5]

    In June 2011, Davis asked for the day of July 3, 2011, off "due to a previous religious commitment." Her supervisor did not approve the absence, saying it "would be grounds for a write-up or termination." When Davis did not go to work on July 3, Fort Bend County terminated her employment.[6]

    The Texas Workforce Commission gave Davis a right-to-sue letter. She sued the county in federal district court, alleging retaliation and religious discrimination under Title VII of the Civil Rights Act of 1964. Title VII requires plaintiffs to file charges of employment discrimination with the federal Equal Employment Opportunity Commission (EEOC) within 180 days of the alleged discrimination before filing suit in federal court.[3][4][5]

    The district court ruled in favor of Fort Bend County and Davis appealed. The 5th Circuit affirmed the district court's decision on the retaliation claim but reversed and remanded the court's decision regarding Davis' religious discrimination claim.[5] On remand, the district court determined that Davis had not exhausted the administrative remedies Title VII required before she had filed a federal lawsuit.[5]

    In its ruling, the district court said administrative exhaustion was a jurisdictional requirement in Title VII cases, meaning a federal court cannot hear employment discrimination claims if the plaintiff has not first completed the administrative process. The court dismissed Davis' religious discrimination claim.[5]

    The 5th Circuit again reversed the district court's ruling. Judge Jennifer Elrod wrote that differing 5th Circuit panels reached differing conclusions on whether filing a charge with the EEOC was a requirement for federal courts to review Title VII claims or if the requirement could be waived.[4][7] The 5th Circuit's ruling that the administrative exhaustion requirement could be waived was consistent with rulings from the 1st, 2nd, 3rd, 6th, 7th, 10th, and D.C. Circuits. It was inconsistent with rulings from the 4th, 9th, and 11th Circuits.[5]

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    • Whether Title VII's administrative exhaustion requirement is a jurisdictional prerequisite to suit, as three Circuits have held, or a waivable claim-processing rule, as eight Circuits have held.

    Outcome

    In a unanimous opinion, the court affirmed the 5th Circuit's ruling, holding a federal court can hear claims under Title VII of the Civil Rights Act of 1964 even if the plaintiff has not completed an administrative process required under Title VII. Justice Ruth Bader Ginsburg delivered the opinion of the court.[1]

    Opinion

    In her opinion, Justice Ginsburg wrote:[1]

    “ When the EEOC receives a charge, in contrast to agencies like the National Labor Relations Board, 29 U. S. C. §160, and the Merit Systems Protection Board, 5 U. S. C. §1204, it does not "adjudicate [the] clai[m]," Alexander v. Gardner-Denver Co., 415 U. S. 36, 44 (1974). Instead, Title VII calls for the following course. Upon receiving a charge, the EEOC notifies the employer and investigates the allegations. 42 U. S. C. §2000e–5(b). If the Commission finds "reasonable cause" to believe the charge is true, the Act instructs the Commission to "endeavor to eliminate [the] alleged unlawful employment practice by informal methods of conference, conciliation, and persuasion." Ibid. When informal methods do not resolve the charge, the EEOC has first option to "bring a civil action" against the employer in court. §2000e–5(f )(1). ...


    In the event that the EEOC determines there is "n[o] reasonable cause to believe that the charge is true," the Commission is to dismiss the charge and notify the complainant of his or her right to sue in court. 42 U. S. C. §2000e–5(b), f(1); 29 CFR §1601.28. Whether or not the EEOC acts on the charge, a complainant is entitled to a "right-to-sue" notice 180 days after the charge is filed. §2000e–5(f )(1); 29 CFR §1601.28. And within 90 days following such notice, the complainant may commence a civil action against the allegedly offending employer. §2000e–5(f )(1). [8]

    		”

    Text of the opinion

    Read the full opinion here.

    Audio



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Supreme Court of the United States, Fort Bend County, Texas v. Davis, June 3, 2019
    2. ↑ SCOTUSblog, "Fort Bend County, Texas v. Davis," accessed March 27, 2019
    3. ↑ 3.0 3.1 3.2 Supreme Court of the United States, "18-525 Fort Bend County, TX v. Davis: Questions presented," accessed March 27, 2019
    4. ↑ 4.0 4.1 4.2 United States Court of Appeals for the 5th Circuit, Davis v. Fort Bend County, June 20, 2018
    5. ↑ 5.0 5.1 5.2 5.3 5.4 5.5 Cite error: Invalid <ref> tag; no text was provided for refs named oyez
    6. ↑ United States Court of Appeals for the 5th Circuit, Davis v. Fort Bend County, August 26, 2014
    7. ↑ SCOTUSblog, "Eight new grants, Ginsburg recovery from surgery 'on track,'" January 11, 2019
    8. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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