Fort Bend Cnty. v. Davis
The Supreme Court ruled that a company waited too long to argue a worker's lawsuit should be dismissed because she hadn't listed her religious-discrimination claim in her initial complaint to the federal agency that handles workplace bias.
The Court held that this filing requirement, while mandatory when raised promptly, is not the kind of bedrock 'jurisdictional' rule that can be sprung on a court years into litigation, so the county forfeited the objection by waiting too long to raise it.
“Prerequisites to suit like Title VII's charge-filing instruction are not of that character; they are properly ranked among the array of claim-processing rules that must be timely raised to come into play.”
The Court's core holding on how to classify Title VII's charge-filing requirement.
How it got here: A federal trial court ruled against the worker; the county did not challenge the charge-filing issue until years later, after one trip to the Supreme Court; the Fifth Circuit found the objection forfeited.
The Case in Depth
What happened
A county IT employee reported that her supervisor's colleague was sexually harassing her. After he resigned, she says her supervisor retaliated against her, eventually firing her after she chose to attend a church commitment instead of coming to work on a Sunday. She had filed an EEOC intake form mentioning religion but her formal charge covered only the harassment and retaliation.
The question before the Court
Can an employer wait years into a lawsuit, all the way through one trip to the Supreme Court, before arguing the case should be thrown out because the employee's discrimination claim was never included in her EEOC complaint?
Why it matters
Employers can no longer sit on objections about missing EEOC paperwork and spring them late in a case to escape liability after years of litigation. Workers get more certainty that a lawsuit won't be tossed on a technicality raised at the last minute, and employers now have a strong incentive to flag any filing problems immediately.
What changes now
This is a final merits decision. Because the county forfeited its objection by raising it too late, the worker's religious-discrimination claim may proceed in the lower courts on the merits. The ruling also clarifies, for future cases nationwide, that defendants must raise objections to a missing or incomplete EEOC charge promptly or risk losing the argument entirely.
What this does not decide
The Court did not decide whether the worker's religious-discrimination claim actually has merit, nor did it decide any broader question about when other statutory preconditions to suit might count as jurisdictional. It addressed only whether Title VII's charge-filing requirement itself is jurisdictional.
How the Court got there
The legal reasoning, step by step
- The Court explained that 'jurisdictional' is a label reserved for rules defining which kinds of cases a court can hear (subject-matter jurisdiction) or which people it can bind (personal jurisdiction) — not just any important legal requirement.
- The Court distinguished jurisdictional rules from mandatory claim-processing rules, which require parties to take certain steps at certain times but can be forfeited if the other side waits too long to object.
- Looking at Title VII's text, the Court found that the charge-filing requirement appears in separate provisions from the law's actual grant of federal-court jurisdiction, and neither provision refers to a court's authority to hear the case.
- Because Congress did not attach the charge-filing rule to Title VII's jurisdictional grant or clearly label it jurisdictional, the Court applied its rule that ambiguous requirements are treated as nonjurisdictional processing rules rather than jurisdictional bars.
- The Court rejected the county's argument that the requirement should be jurisdictional simply because it serves important goals like encouraging conciliation, noting that serving an important purpose does not by itself make a rule jurisdictional.
- Applying this framework, the Court concluded the charge-filing rule is a mandatory but forfeitable claim-processing rule, and the county lost its chance to raise it by waiting until years into the litigation.