Caylor v. City of Red Bluff

Background

A person sued in a California court claiming employment discrimination under federal civil‑rights law without first filing a complaint with the California Fair Employment Practices Commission. The California Court of Appeal held that earlier federal cases on this issue applied only to federal courts and dismissed the state lawsuit because the plaintiff had not pursued the state agency complaint first. The plaintiff asked the Supreme Court to review that ruling, but the Court denied review.

Reasoning

The central question is whether someone suing under federal civil‑rights law in a state court must first try remedies with the state employment agency. Justice White’s dissent explains that a 1982 decision, Patsy v. Florida Board of Regents, said federal courts do not require that prior step, and he argues the California court should not either. The dissent also notes a Connecticut case, Fetterman v. University of Connecticut, which reached the opposite conclusion by holding that Patsy prevents state courts from imposing the agency‑first requirement. Justice White would have granted review to resolve that conflict.

Real world impact

Because the Supreme Court declined to take the case, the California rule requiring an initial complaint to the state employment agency stays in effect for this plaintiff and similar cases in that court. The lower‑court dismissal remains in place and the disagreement between state courts about applying Patsy is unresolved nationally. This decision is a denial of review, not a final ruling on the broader legal question.

Dissents or concurrances

Justice White, joined by Justice Brennan, dissented from the denial of review and would have granted the case to decide whether state courts can require the state‑agency step before federal civil‑rights suits.