Crown, Cork & Seal Co. v. Parker

1983-06-13

Headline: Filing a class action pauses Title VII’s lawsuit deadline; Court affirms that a class filing tolls the deadline, allowing individual class members to sue after certification denial if they file within remaining time.

Holding: In this Title VII case, the Court held that the filing of a class action tolls the statute of limitations for all asserted class members, allowing them to bring timely individual suits after denial of class certification.

Real World Impact:

Allows class members to file individual suits after certification denial without losing time.
Treats a class filing as notice prompting defendants to preserve evidence and witnesses.
Reduces need for protective filings or rushed interventions by proposed class members.

Topics: class actions, deadlines for lawsuits, workplace racial discrimination, EEOC complaints

Summary

Background

The dispute involved Theodore Parker, a Black worker who was fired in July 1977 and who filed an EEOC complaint in October 1977. While his EEOC charge was pending, other former employees filed a class action alleging racial discrimination by the same employer. The class asked for certification, but the District Court denied certification on September 4, 1980. Parker then filed his own Title VII suit on October 27, 1980, within 90 days after the denial but long after he had received a Notice of Right to Sue. The District Court dismissed his suit as time-barred, but the Court of Appeals reversed.

Reasoning

The core question was whether the filing of a class action stops (tolls) the running of the deadline for individual class members to bring suit. The Court relied on its earlier American Pipe decision and held that the commencement of a class action suspends the statute of limitations for all asserted class members who would have been parties if the suit continued as a class action. The Court explained that a class filing gives defendants notice of the claims and the group affected and prevents needless protective filings. Because the Pendleton class suit was filed before Parker’s Notice of Right to Sue, the limitations period was tolled and Parker’s later individual suit was timely.

Real world impact

The ruling lets people in proposed classes rely on a pending class lawsuit to preserve their claims rather than rush to file separate protective suits or intervene. Employers are put on notice to preserve evidence and witnesses for potential class members. The decision does not free claimants to raise entirely different claims than those the class complaint described.

Dissents or concurrances

Justice Powell, joined by Justices Rehnquist and O’Connor, concurred but cautioned against abuse: separate suits must concern the same evidence and claims fairly noticed by the class complaint to avoid unfair prejudice to defendants.