Oscar Mayer & Co. v. Evans

Background

Joseph Evans worked for Oscar Mayer for 23 years and says he was forced to retire because of his age. He filed a federal notice of intent to sue and, after getting advice from the Department of Labor that no state filing was required, did not file a state complaint. When he later sued in federal court, the company argued that Iowa’s agency could handle the claim first under the ADEA’s §14(b).

Reasoning

The Court addressed whether §14(b) requires workers in states with age-discrimination agencies to seek state administrative relief before filing a federal ADEA suit, and whether state time limits must be met to satisfy that requirement. The majority compared §14(b) to a similar Title VII provision and concluded that prior resort to appropriate state proceedings is mandatory. The Court also held that §14(b) requires only that state proceedings be commenced; filing a state complaint counts as commencement even if a state limitations period has passed.

Real world impact

Workers in states that enforce age-discrimination laws must file with the state agency before their federal ADEA cases proceed. Federal courts should hold ADEA suits in abeyance while the state agency is given an opportunity to act for up to 60 days. If the state later dismisses a claim as untimely, the worker may return to federal court.

Dissents or concurrances

Some Justices agreed only in part. One Justice preferred affirming the lower court; another would have dismissed the federal suit rather than advise the plaintiff to file in state agency and hold the case in abeyance.