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Johnson v. Railway Express Agency, Inc.

Supreme Court of the United States
1975 U.S. LEXIS 15, 421 U.S. 454, 44 L. Ed. 2d 295 (1975)
ELI5:

Rule of Law:

The timely filing of an employment discrimination charge with the Equal Employment Opportunity Commission (EEOC) under Title VII does not toll (pause) the running of the applicable state statute of limitations for a separate cause of action based on the same facts under 42 U.S.C. § 1981.


Facts:

  • In the spring of 1964, Willie Johnson, Jr., a Negro man, began working for Railway Express Agency, Inc. (REA).
  • On May 31, 1967, Johnson filed a charge with the EEOC alleging that REA discriminated against its Negro employees regarding seniority and job assignments.
  • Johnson also charged the Brotherhood of Railway Clerks unions with maintaining racially segregated memberships.
  • On June 20, 1967, three weeks after he filed the charge, REA terminated Johnson's employment.
  • Following his termination, Johnson amended his EEOC charge to allege that he had been discharged because of his race.

Procedural Posture:

  • Willie Johnson, Jr. filed a right-to-sue letter and then a supplemental complaint in the U.S. District Court for the Western District of Tennessee, alleging violations of Title VII and 42 U.S.C. § 1981.
  • The District Court dismissed the § 1981 claims as barred by Tennessee’s one-year statute of limitations.
  • Johnson, as the appellant, appealed the dismissal to the U.S. Court of Appeals for the Sixth Circuit.
  • The Court of Appeals affirmed the District Court's judgment, agreeing that the § 1981 claim was time-barred and that the statute of limitations was not tolled by the EEOC filing.
  • The U.S. Supreme Court granted certiorari, limited to the issue of whether the EEOC filing tolled the statute of limitations for the § 1981 claim.

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Issue:

Does the timely filing of an employment discrimination charge with the Equal Employment Opportunity Commission (EEOC) under Title VII of the Civil Rights Act of 1964 toll the running of the applicable state statute of limitations for a cause of action under 42 U.S.C. § 1981 based on the same facts?


Opinions:

Majority - Justice Blackmun

No. The filing of a Title VII charge with the EEOC does not toll the statute of limitations for a § 1981 action because the two remedies are separate, distinct, and independent. The court reasoned that Congress intended for Title VII and § 1981 to be parallel and independent avenues for relief against employment discrimination. Since § 1981 does not have its own statute of limitations, federal courts must borrow the most appropriate state statute of limitations, and with it, the state's tolling provisions. The court found no inconsistency between state tolling rules and federal policy that would justify creating a federal tolling rule in this context. The petitioner's failure to file his § 1981 claim within the state's one-year period was not excused by his pending EEOC claim; in essence, he 'slept on his § 1981 rights.'


Concurring-in-part-and-dissenting-in-part - Justice Marshall

Yes. While agreeing that Title VII and § 1981 are independent remedies, the dissent argues that the statute of limitations for a § 1981 action should be tolled during the pendency of EEOC proceedings. The majority's holding undermines the strong federal policy of encouraging conciliation and voluntary compliance through the EEOC, as it forces aggrieved individuals into 'premature and expensive litigation' to preserve their § 1981 rights. The purposes of a statute of limitations—to prevent stale claims and unfair surprise—are not served by barring the claim here, because the EEOC charge provided the employer with timely notice of the grievance. Federal equity principles should be applied to toll the statute in order to harmonize the comprehensive set of remedies Congress created to combat employment discrimination.



Analysis:

This decision solidifies the legal independence of Title VII and § 1981, but it creates a significant practical challenge for employment discrimination plaintiffs. By refusing to toll the § 1981 statute of limitations, the Court requires plaintiffs to initiate federal litigation while simultaneously pursuing administrative remedies, potentially undermining the EEOC's non-adversarial conciliation process. This ruling forces plaintiffs' attorneys to be vigilant in tracking multiple, independent deadlines for different statutory claims arising from the same facts. In effect, it prioritizes the strict, independent nature of the remedies over the federal policy goal of resolving disputes through administrative conciliation before resorting to the courts.

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