Mohasco Corp. v. Silver

1980-06-23

Headline: Workplace discrimination filing rules clarified — Court holds EEOC receipt during state deferral does not count as filing, making federal suits untimely unless state deferral ends within the federal 300‑day window.

Holding: The Court held that an EEOC receipt during a state deferral period is not a federal "filing" for the 300‑day limit until the deferral ends, so the employee’s suit was untimely.

Real World Impact:

Clarifies filing deadline calculation for discrimination claims in deferral States.
Makes EEOC receipt during state deferral not count toward the 300‑day deadline.
Pushes complainants to file earlier to preserve federal claims.

Topics: workplace discrimination filing rules, EEOC procedures, statute of limitations, state‑federal coordination

Summary

Background

A company fired a senior marketing economist on August 29, 1975. Nearly ten months later (June 15, 1976) the former employee sent a letter to the federal Equal Employment Opportunity Commission (EEOC) claiming religious discrimination. The EEOC immediately sent that letter to the New York State Division of Human Rights, which later found no probable cause. The employee sued in federal court after receiving the EEOC’s final notice, but the employer argued the initial complaint had not been filed with the EEOC within the required time limits.

Reasoning

The core question was whether a complaint the EEOC received while it had to defer to a state agency should count as “filed” for the federal 300‑day limit. The Court read the statute literally and relied on prior guidance that the EEOC may hold a complaint in “suspended animation” while state proceedings run. Under that reading, the complaint is only treated as filed when the deferral ends or the state proceedings terminate. Because the state deferral outlasted the 300‑day period, the Court concluded the employee’s letter was not a timely filing and the federal suit was barred.

Real world impact

The decision makes clear that sending a complaint to the EEOC during a mandatory state deferral period will not preserve a complainant’s federal 300‑day deadline unless the state proceedings end within that federal window. Claimants in states with deferral agencies must therefore act earlier or risk losing federal remedies. The ruling enforces the statutory timetable Congress set in Title VII.

Dissents or concurrances

A dissent argued the Court ignored legislative history and the EEOC’s longtime practice of treating such submissions as timely, warning the majority’s rule creates confusing “240‑day maybe” outcomes.