Alexander v. Gardner-Denver Co.
415 U.S. 36 (1974)
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Rule of Law:
An employee's submission of a discrimination claim to final arbitration under a collective-bargaining agreement does not waive or foreclose their statutory right to a subsequent trial de novo in federal court under Title VII of the Civil Rights Act of 1964. The contractual rights under a collective-bargaining agreement and the statutory rights under Title VII are separate and independent remedies that may be pursued in parallel.
Facts:
- In May 1966, Harrell Alexander, Sr., a black man, was hired by Gardner-Denver Co. for maintenance work.
- In June 1968, Alexander was promoted to a trainee position as a drill operator.
- On September 29, 1969, Gardner-Denver Co. discharged Alexander, stating it was for producing too many defective parts.
- Alexander filed a grievance under the collective-bargaining agreement (CBA), which contained clauses for 'just cause' discharge and a prohibition on racial discrimination.
- The CBA also contained a multi-step grievance procedure culminating in compulsory and binding arbitration.
- During the pre-arbitration process, Alexander raised for the first time the claim that his discharge was the result of racial discrimination.
- At the arbitration hearing, Alexander testified that his discharge was due to racial discrimination.
Procedural Posture:
- Harrell Alexander, Sr. pursued a grievance against Gardner-Denver Co. through his union's arbitration machinery.
- The arbitrator ruled on December 30, 1969, that Alexander was discharged for 'just cause' and did not reference the racial discrimination claim.
- Prior to the arbitration hearing, Alexander filed a racial discrimination charge with the Colorado Civil Rights Commission, which referred it to the federal Equal Employment Opportunity Commission (EEOC).
- On July 25, 1970, the EEOC determined there was not reasonable cause to believe a violation of Title VII had occurred and issued Alexander a notice of his right to sue.
- Alexander then filed suit in the United States District Court for the District of Colorado, alleging a violation of Title VII.
- The District Court granted summary judgment for Gardner-Denver Co., holding that Alexander was bound by the prior arbitral decision.
- The U.S. Court of Appeals for the Tenth Circuit affirmed the District Court's decision.
- The U.S. Supreme Court granted certiorari to review the case.
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Issue:
Does an employee's prior submission of a discrimination claim to final arbitration under a collective-bargaining agreement foreclose their statutory right to a trial de novo under Title VII?
Opinions:
Majority - Justice Powell
No. An employee's statutory right to a trial de novo under Title VII is not foreclosed by prior submission of their claim to final arbitration under a collective-bargaining agreement. The court reasoned that Title VII grants federal courts plenary power to enforce statutory rights against employment discrimination, and the legislative history shows an intent to allow individuals to pursue parallel and overlapping remedies. An employee's rights under a collective-bargaining agreement are contractual, seeking to vindicate private rights based on the bargain between the company and the union, while Title VII rights are statutory, seeking to vindicate public policy. An arbitrator's authority is limited to interpreting the contract ('the law of the shop'), not public law, and arbitral procedures are less formal and protective than judicial procedures, making arbitration an inappropriate forum for the final resolution of statutory rights. Thus, an employee does not waive their Title VII cause of action by first pursuing a contractual grievance remedy.
Analysis:
This landmark decision establishes that rights granted by federal statutes like Title VII exist independently of any contractual rights an employee may have under a collective-bargaining agreement. It firmly places the ultimate enforcement authority for Title VII with the federal courts, preventing private agreements from waiving an individual's statutory protections against discrimination. This ruling ensures that employees have multiple avenues for redress and that the choice of one (arbitration) does not preclude the other (litigation), thereby strengthening the enforcement mechanism of federal anti-discrimination law.
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