Chardon v. Fernandez

1982-01-11

Headline: Court limits timing for job-termination civil-rights suits, ruling the statute of limitations starts when employees receive written notice of termination, making many delayed claims by nontenured public employees time-barred.

Holding: The Court held that a civil-rights claim based on a planned job termination begins to run when the employee is notified of the termination decision, so the statute of limitations starts at notice rather than when employment ends.

Real World Impact:

Many delayed civil-rights suits by nontenured public employees become time-barred.
Employees must file sooner after written notice, or risk losing their claims.
Encourages earlier injunctive actions but limits later damages claims.

Topics: employment terminations, statute of limitations, public employees, civil rights suits

Summary

Background

Respondents were nontenured administrators in the Puerto Rico Department of Education who received letters before June 18, 1977 saying their appointments would end between June 30 and August 8, 1977. One respondent filed a lawsuit on June 19, 1978, saying the planned terminations violated his civil rights. The District Court held the claims were too late because the clock began when the employees got the termination letters; the Court of Appeals disagreed and said the clock began when the appointments actually ended.

Reasoning

The central question was when a lawsuit for an allegedly unlawful job termination starts for statute-of-limitations purposes: at the time the employer made and announced the decision, or when the termination actually takes effect. The Court said the key moment is the discriminatory act and the notice of it, not the later end of employment. Because the decision and notice were given in advance, the Court held the limitations period began when the employees received those letters, so many claims filed later are legally too late.

Real world impact

The ruling affects nontenured public employees who receive advance notice of termination: they must bring lawsuits sooner after receiving notice or risk being barred. The Court reversed the appeals court judgments and sent the cases back for further steps consistent with this timing rule. The decision narrows when a damages claim can start and pushes many disputes to be raised earlier, sometimes before the job actually ends.

Dissents or concurrances

Justices Brennan and Stevens dissented, arguing the rule is inappropriate and that the limitations period should run from the date the termination is actually implemented; they warned the majority’s rule will prompt premature or anticipatory lawsuits.