Delaware State College v. Ricks

1980-12-15

Headline: Ruling bars a college professor’s discrimination lawsuit as filed too late, holding filing deadlines begin when a tenure denial is communicated, not when a later terminal contract expires, affecting employees on short contracts.

Holding: The Court held that a professor’s discrimination claims were untimely because filing deadlines begin when an employer’s adverse tenure decision is communicated, not when a later one-year terminal contract ends.

Real World Impact:

Requires employees to file discrimination charges from the date the adverse tenure decision is communicated.
Allows colleges to avoid suits if claims are filed after the statutory deadline.
Limits when teachers on terminal contracts can bring federal discrimination suits.

Topics: employment discrimination, academic tenure, filing deadlines, EEOC claims

Summary

Background

A college professor who is a black Liberian was denied tenure at a state college after faculty and the board voted against him. The board told him on June 26, 1974, that he would be offered a one-year "terminal" contract ending June 30, 1975; he signed that contract and the board later denied his grievance on September 12, 1974. He filed an administrative charge in 1975 and sued in federal court in 1977, alleging discrimination based on national origin under the federal civil rights laws (Title VII and § 1981).

Reasoning

The Court addressed when the deadlines for filing discrimination claims begin to run. It held that the clock starts when the employer makes and communicates the adverse tenure decision, not when a later terminal contract ends. The Court found the complaint described only the denial of tenure and contained no allegation that the later termination itself was separately discriminatory. Because the required administrative filing and the lawsuit were filed after the applicable time limits, the Court concluded the claims were untimely and reversed the Court of Appeals.

Real world impact

The decision means employees denied tenure or given short terminal contracts must act promptly and file within the statutory deadlines that begin when the adverse decision is communicated. It favors employers in similar situations by making late-filed claims harder to bring and discourages waiting until a terminal contract expires to start a claim.

Dissents or concurrances

Dissenting Justices argued the complaint could plausibly claim the denial was not final until September 12, 1974, or that the effective discharge date (June 30, 1975) should control; they would have allowed further fact-finding.