Goodman v. Lukens Steel Co.

Background

Workers at Lukens Steel sued their employer and their union representatives in 1973, alleging racial discrimination under Title VII and 42 U.S.C. §1981. After a lengthy bench trial, the District Court found discrimination by the company and by the unions for failing to challenge discriminatory discharges of probationary employees, refusing to assert racial discrimination as grievances, and tolerating racial harassment. The District Court initially used a six-year state limitations period for §1981 claims; the Court of Appeals applied a two-year personal-injury period instead.

Reasoning

The Supreme Court addressed two main questions: which state statute of limitations applies to §1981 claims, and whether the unions were legally liable for their grievance practices. Relying on prior Supreme Court guidance, the majority held §1981 claims should be characterized like personal-injury claims for limitations purposes and therefore borrowed Pennsylvania’s two-year personal-injury period for this case. The Court also affirmed the lower courts’ factual findings that the unions deliberately chose not to press racial grievances, concluding that such intentional refusal to pursue race-based complaints violated both Title VII and §1981.

Real world impact

The ruling shortens the achievable back-period for many §1981 employment claims in Pennsylvania by applying a two-year limit in this case and confirms unions can be held liable when they knowingly refuse to pursue valid racial grievances. The Court applied the limitations rule to the parties here, and the unions’ liability was affirmed on the facts found below.

Dissents or concurrances

Justices Brennan (joined by Marshall and Blackmun) dissented on the limitations issue, arguing §1981 should borrow longer contract-based periods. Justices Powell and O’Connor would have remanded or vacated the unions’ liability for further factual clarification.