Burnett v. Grattan

1984-06-27

Headline: Court rejects Maryland’s six‑month administrative deadline for federal civil‑rights suits and upholds use of the state’s three‑year general limit, easing timing rules for employees suing over discrimination.

Holding: The Court held that Maryland’s six‑month administrative filing deadline is not an appropriate statute of limitations for federal civil‑rights lawsuits and affirmed applying the state’s three‑year general limitations period to the claims.

Real World Impact:

Prevents use of six‑month state administrative deadlines for federal civil‑rights lawsuits.
Allows federal plaintiffs to rely on Maryland’s three‑year general limitations period.
Resolves conflicting court approaches about borrowing state deadlines in civil‑rights cases.

Topics: employment discrimination, statute of limitations, civil rights lawsuits, state vs federal law

Summary

Background

James Grattan and Adrienne Hedman were white employees at Coppin State College who received notice in June 1976 that their contracts would not be renewed. They filed federal EEOC complaints and then a state court lawsuit in February 1977, amending it in October 1981 to assert racial and gender discrimination claims under federal civil‑rights laws. After removal to federal court, the District Court applied Maryland’s six‑month administrative filing deadline in Art. 49B §9(a) and dismissed the suit as time‑barred; the Fourth Circuit instead applied Maryland’s three‑year general limitations period and reinstated most claims. The Supreme Court agreed to decide which state deadline federal courts should borrow.

Reasoning

The Court examined 42 U.S.C. §1988, which directs federal courts to borrow state rules when federal law is silent. It held the six‑month administrative deadline was inappropriate to govern federal civil‑rights lawsuits because Maryland’s administrative process is informal, investigatory, and geared to quick conciliation with limited remedies. By contrast, federal civil‑rights suits are judicial, can seek money damages and injunctions, and require more preparation by plaintiffs. Those functional and policy differences made the administrative filing period a poor fit, so the Court affirmed applying Maryland’s general three‑year civil‑action limitation.

Real world impact

The decision prevents short state administrative deadlines from cutting off federal civil‑rights claims and allows injured employees to rely on a longer general limitations period. It resolves conflicting approaches among federal appeals courts and restores most of the respondents’ claims (the First Amendment claim was separately time‑barred). The ruling clarifies how federal courts should choose state time limits when federal statutes are silent.

Dissents or concurrances

Justices Powell and Rehnquist joined the judgment. Powell simply agreed; Rehnquist agreed with the result but argued courts should begin by determining the state legislature’s intent in selecting a limitations period.