Delaware State College v. Ricks
66 L. Ed. 2d 431, 449 U.S. 250, 1980 U.S. LEXIS 161 (1980)
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Rule of Law:
The statute of limitations for an employment discrimination claim begins to run at the time the discriminatory act occurs and is communicated to the employee, not when the consequences of that act, such as the eventual termination of employment, take effect.
Facts:
- Columbus Ricks, a black Liberian professor, was hired by Delaware State College in 1970.
- In February 1974, after a year of reconsideration, the college's tenure committee maintained its recommendation to deny Ricks tenure.
- On March 13, 1974, the College Board of Trustees formally voted to deny tenure to Ricks.
- Following the denial, Ricks immediately filed an internal grievance with the Board's Educational Policy Committee.
- On June 26, 1974, while the grievance was pending, the College notified Ricks that he would be offered a one-year terminal contract set to expire on June 30, 1975.
- Ricks signed the terminal contract on September 4, 1974.
- On September 12, 1974, the Board of Trustees informed Ricks that his grievance had been denied.
- Ricks's employment with the college officially ended on June 30, 1975.
Procedural Posture:
- Columbus Ricks filed suit in the U.S. District Court against Delaware State College, alleging employment discrimination under Title VII and 42 U.S.C. § 1981.
- The District Court granted the College's motion to dismiss both claims as untimely.
- Ricks, as appellant, appealed to the U.S. Court of Appeals for the Third Circuit, with the College as appellee.
- The Court of Appeals reversed the District Court's dismissal, holding that the limitations period began on the date Ricks's terminal contract expired.
- The U.S. Supreme Court granted certiorari to review the judgment of the Court of Appeals.
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Issue:
Does the limitations period for an employment discrimination claim based on a denial of tenure begin on the date the employee's terminal contract expires, rather than when the adverse tenure decision is made and communicated?
Opinions:
Majority - Justice Powell
No. The limitations period for an employment discrimination claim commences when the alleged discriminatory act is made and communicated to the employee. The proper focus is on the discriminatory act itself, which in this case was the denial of tenure, not on the later, inevitable consequences of that act, such as the final day of employment. The Court reasoned that mere continuity of employment does not prolong the life of a cause of action, and the termination was a delayed effect of the tenure denial, not a separate discriminatory act. Furthermore, citing Electrical Workers v. Robbins & Myers, Inc., the pendency of an internal grievance procedure does not toll (or pause) the running of the limitations period. Therefore, the statute of limitations began to run no later than June 26, 1974, when the college's official position was made apparent to Ricks, rendering his subsequent filings untimely.
Dissenting - Justice Stewart
No, but the majority identifies the wrong date for when the decision was communicated. A plausible reading of the facts suggests the college did not effectively deny Ricks tenure until September 12, 1974, the date his grievance was formally denied. The June 26 letter from the Board of Trustees indicated the decision was not final, stating that a favorable outcome from the grievance process would 'supersede any previous action taken by the Board.' Ricks should have been allowed to prove that this later date was when the final, discriminatory decision occurred, which would have made his claims timely.
Dissenting - Justice Stevens
Yes. The limitations period should begin on the effective date of the discharge, which was the final day of the terminal contract. This situation is analogous to an employer giving an employee advance notice of termination. The most sensible rule would establish the accrual of the cause of action on the date the discharge becomes effective, as this date is the most certain and identifiable. This rule would also promote harmonious working relations during the terminal period by not forcing an employee to file a claim against their employer while still employed.
Analysis:
This decision established a pivotal rule for the timeliness of employment discrimination claims, clarifying that the limitations period 'accrues' at the moment of the discriminatory act, not when its effects are fully felt. By rejecting the 'last day of employment' as the start date, the Court placed the burden on employees to file claims promptly after being notified of an adverse decision. This ruling significantly impacts cases involving tenure denials or any situation with a gap between notice of termination and the actual separation date, foreclosing claims for those who wait until their employment ends to seek legal recourse. It also affirmed that internal grievance procedures do not pause the statutory clock for filing a formal discrimination charge.
