International Union of Electrical, Radio & MacHine Workers v. Robbins & Myers, Inc.
Headline: Court applies extended 180-day EEOC filing deadline retroactively, reverses appeals court, but rejects tolling of the deadline during union grievance procedures, affecting workers pursuing discrimination claims.
Holding: The Court held that Congress’s 1972 extension of the EEOC filing deadline to 180 days applies to Guy’s charge filed before enactment, but the Court rejected tolling during union grievance and arbitration procedures.
- Allows some charges filed before March 24, 1972 to use a 180-day EEOC deadline.
- Stops union grievance procedures from pausing the federal discrimination filing deadline.
- Reopens some previously barred suits for further court consideration.
Summary
Background
Dortha Guy, a Black employee, was fired by her employer, Robbins & Myers, Inc., on October 25, 1971. Two days later her union, Local 790, filed a grievance under the collective-bargaining agreement. The grievance went through three steps and was denied on November 18, 1971. Guy then filed a charge of racial discrimination with the EEOC on February 10, 1972. At the time of her discharge, Title VII required charges to be filed within 90 days of the alleged unlawful act, and Guy’s charge was filed 108 days after the discharge.
Reasoning
The Court considered whether pursuing the union grievance delayed the start of the 90-day period or tolled (paused) that period, and whether Congress’s March 24, 1972 law extending the EEOC deadline to 180 days applied to Guy’s charge. Relying on prior decisions, the Court held that grievance and arbitration procedures under a collective-bargaining agreement do not toll the Title VII filing period because contractual remedies are independent of statutory Title VII rights. At the same time, the Court read the 1972 Act to apply the new 180-day deadline to charges like Guy’s that were filed before enactment but alleged occurrences within 180 days of the law.
Real world impact
The Court reversed the Court of Appeals and sent the case back for further proceedings under the expanded 180-day rule. The decision means union grievance steps will not pause the federal discrimination filing deadline, yet some charges filed before March 24, 1972 may now be treated as timely under the longer deadline. This ruling is procedural on deadlines and does not resolve whether Guy was unlawfully discharged; the lower courts will continue the case.
Dissents or concurrances
Four Justices said they would have resolved the case solely by applying the 180-day amendment and would not have reached the tolling questions.
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