Saturday, May 4, 2013

National R.R. Passenger Corp. v. Morgan case brief

National R.R. Passenger Corp. v. Morgan case brief
536 U.S. 101

CASE SYNOPSIS: Respondent former employee sued petitioner former employer under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., some of his claims were dismissed as untimely, but the United States Court of Appeals for the Ninth Circuit had held that his claims were not time barred so long as they were sufficiently related to incidents that fell within the statutory period.

FACTS: The court held that since the employee's hostile work environment claim was comprised of a series of separate acts that collectively constituted one unlawful employment practice, the timely filing provision only required that he file a charge within a certain number of days after the unlawful practice happened. It did not matter, for purposes of the statute, that some of the component acts of the hostile work environment fell outside the statutory time period. Provided that an act contributing to the claim occurred within the filing period, the entire time period of the hostile environment may be considered by a court for the purposes of determining liability. The court went on to note that the application of equitable doctrines may either limit or toll the time period within which an employee must file a charge.

CONCLUSION: The judgment was affirmed in that many of the acts upon which the employee's hostile environment claim depended were allowed to be considered despite having had occurred outside the 300 day filing period. The judgement was reversed as to that part which held that so long as one act falls within the period, discriminatory and retaliatory acts that are plausibly or sufficiently related to that act may also be considered for liability.

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