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18-525 FORT BEND COUNTY, TX V. DAVIS DECISION BELOW: 893 F.3d 300 CERT. GRANTED 1/11/2019 QUESTION PRESENTED: Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., requires plaintiffs to exhaust claims of employment discrimination with the EEOC before filing suit in federal court. Id. § 2000e-5(b), (f)(1). The question presented is: 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. LOWER COURT CASE NUMBER: 16-20640
In the case of Fort Bend County, Texas v. Davis (2018), Lois M. Davis filed a lawsuit against her employer, Fort Bend County, for sexual harassment and retaliation after she reported the misconduct. However, during litigation proceedings it was discovered that one of her claims had not been included in her initial complaint to the Equal Employment Opportunity Commission (EEOC). The county argued this omission meant that federal courts lacked jurisdiction over this claim due to failure to exhaust administrative remedies before filing suit - a requirement under Title VII of Civil Rights Act 1964. The Supreme Court ruled in favor of Davis stating that while plaintiffs are generally required to raise all complaints with EEOC before proceeding with legal action; such requirements are procedural rather than jurisdictional. Therefore, if an employer does not promptly object on these grounds at an early stage in proceedings they may forfeit their right to have them dismissed based on non-compliance with these rules.
In the case of Fort Bend County, Texas v. Davis, there was no dissenting opinion recorded as the judgment was unanimous. The Supreme Court ruled in favor of Lois M. Davis, holding that Title VII’s charge-filing requirement is not a jurisdictional prerequisite to suit but rather a prudish prescription which can be forfeited if it is not timely asserted by an employer-defendant. This means that if an employee fails to properly file a complaint with the Equal Employment Opportunity Commission (EEOC) before suing their employer for discrimination under Title VII and the employer does not promptly object to this failure, then courts may still hear such cases despite procedural imperfections.