In the 1980 U.S. Supreme Court case Delaware State College et al. v. Ricks, an associate professor of political science at Delaware State College, who was a foreign national from Liberia, claimed that he had been denied tenure due to racial discrimination and filed suit under Title VII of the Civil Rights Act of 1964 and § 1981. The college argued that his denial was based on professional competence rather than race or nationality. The key issue in this case revolved around when the statute of limitations began for filing a claim - whether it started when Ricks was informed about his tenure denial (and given one year "terminal" contract) or after his final employment date with the college. The court ruled in favor of Delaware State College by a vote of seven to two, stating that since Ricks knew about his alleged discriminatory injury when he received notice regarding tenure decision not being in his favor (which happened more than a year before he filed complaint), thus making him ineligible to sue because he did not meet Title VII's requirement which states complaints must be filed within certain time period after alleged unlawful employment practice occurred.

In the dissenting opinion for Delaware State College v. Ricks, Justice Brennan argued that the majority's decision was a misinterpretation of Title VII’s statute of limitations and its purpose. He contended that the Court should have considered when discriminatory effects were felt rather than when decisions were made. In this case, he believed discrimination occurred not at the time tenure was denied but when employment actually ended a year later. Furthermore, he criticized the majority's reliance on cases involving different statutes with distinct legislative histories and purposes to justify their interpretation of Title VII. The dissent also emphasized that Congress intended for victims of discrimination to have ample opportunity to seek redress; thus, starting the clock too early would undermine this intent by prematurely cutting off rights before harm is fully realized or understood.