National Railroad Passenger Corporation v. Morgan
Headline: Court limits lawsuits for old individual workplace discrimination acts but allows full hostile-work-environment claims if any contributing act occurred within the statutory EEOC filing period, affecting employees and employers nationwide.
Holding: The Court held that discrete discriminatory or retaliatory acts are time-barred if not charged within 180 or 300 days, but hostile work environment claims may include earlier acts if at least one contributing act occurred within that filing period.
- Bars suits over individual discriminatory acts older than the 180/300-day filing window.
- Allows hostile-work-environment suits to include earlier incidents if one act was timely.
- Employers can raise laches, estoppel, or tolling defenses against unreasonable delay.
Summary
Background
Abner Morgan, a Black Amtrak employee, filed an EEOC charge alleging repeated racial harassment, disciplinary actions, and retaliation. Some of the acts he complained about occurred more than 300 days before his EEOC filing. The Ninth Circuit applied a continuing-violation approach to allow older incidents to be considered for liability. The Supreme Court reviewed whether events outside the statutory filing window can support Title VII suits.
Reasoning
The Court read the filing statute to require a charge within 180 or 300 days "after the alleged unlawful employment practice occurred." It held that each discrete act (for example, a firing, failure to promote, or suspension) "occurred" on the day it happened and must be charged within the filing period or is time-barred. By contrast, a hostile work environment is a single, ongoing unlawful practice made up of repeated acts, so if at least one act that contributes to that environment fell within the filing period, a court may consider the entire time span when assessing liability. The opinion also notes that equitable doctrines like tolling, estoppel, or laches can limit or extend the filing window in appropriate cases.
Real world impact
Practically, employers may avoid claims based on older isolated acts but cannot always exclude earlier incidents from hostile-environment suits when a timely act exists. Employers retain defenses against unreasonable delay, and courts must decide whether older conduct is part of the same claim.
Dissents or concurrances
Justice O'Connor disagreed with the hostile-environment holding, arguing each day's exposure can be a separate occurrence and that older parts of a hostile environment should be time-barred, to avoid stale claims.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?