In the case of Occidental Life Insurance Company of California v. Equal Employment Opportunity Commission (EEOC), 1976, the U.S Supreme Court ruled in favor of EEOC, stating that a federal court can grant relief to individuals who were not named as complainants before the EEOC but are part of a class for which discrimination was found. The dispute began when an employee filed a complaint with the EEOC alleging sex-based wage discrimination by Occidental Life Insurance Company. After investigation and conciliation attempts failed, EEOC sued on behalf of female employees at Occidental's Los Angeles office under Title VII Civil Rights Act 1964. The District Court dismissed this claim arguing that only those who had lodged complaints could be represented in such suits. However, upon appeal to Ninth Circuit and then Supreme Court, it was held that once employer-wide discriminatory practices have been identified during investigations or conciliations following individual complaints; courts may award relief beyond original complainants without requiring additional filings with EEOC.

In the dissenting opinion for Occidental Life Insurance Company of California v. Equal Employment Opportunity Commission, Justice William Rehnquist argued that the majority's decision to allow EEOC to bring suit on behalf of a complainant after more than 180 days had passed since filing was not in line with the language or intent of Title VII. He contended that Congress intended for private action and government intervention to be parallel enforcement mechanisms, both subject to a 180-day limitation period. By allowing EEOC suits beyond this timeframe, he believed it created an imbalance between these two avenues for redress. Furthermore, he expressed concern over potential due process issues arising from employers being held liable years after alleged discriminatory practices occurred without any prior notice or opportunity to conciliate during those intervening years.