In the case of Leonard Edelman v. Lynchburg College, 2001, the U.S. Supreme Court ruled in favor of Lynchburg College regarding a dispute over Title VII's requirement that an individual must file a charge with Equal Employment Opportunity Commission (EEOC) before bringing suit against their employer for discrimination. The court held that this requirement was not jurisdictional but rather a prudential prerequisite to filing suit and could be waived by courts under certain circumstances. In this specific case, Mr.Edelman filed his lawsuit without first submitting his claim to EEOC as required by law; however, he later included it within his response to the college’s motion for summary judgment after the deadline had passed. The Supreme Court upheld lower court rulings dismissing Edelman's complaint due to late submission of EEOC charges and stated that allowing such post-filing amendments would undermine Congress' intent behind requiring initial resorting to administrative remedies.

In the dissenting opinion for Leonard Edelman v. Lynchburg College, Justice Clarence Thomas argued that the majority's decision to allow a verified complaint to satisfy Title VII’s requirement of a written and sworn charge was inconsistent with both the statute's text and its purpose. He contended that Congress intended for charges to be filed under oath in order to deter false allegations and ensure serious consideration by those filing complaints. The majority’s interpretation, he suggested, would undermine these objectives by allowing unsworn complaints followed later by an oath merely verifying their accuracy. Furthermore, he noted that this approach could potentially lead complainants into making hasty or ill-considered allegations without fully understanding the gravity of swearing under penalty of perjury.