Landgraf v. USI Film Products
511 U.S. 244 (1994)
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Rule of Law:
A statute is presumed to apply prospectively unless Congress expressly states its intent for retroactive application. This presumption against retroactivity applies to new statutory provisions that would increase a party's liability for past conduct or attach new legal consequences to completed events.
Facts:
- From September 1984 to January 1986, Barbara Landgraf was employed at a USI Film Products (USI) plant in Tyler, Texas.
- A fellow employee, John Williams, repeatedly sexually harassed Landgraf with inappropriate remarks and physical contact.
- Landgraf's complaints to her immediate supervisor resulted in no relief.
- Landgraf then reported the incidents to the personnel manager, who conducted an investigation.
- Following the investigation, USI reprimanded Williams and transferred him to another department.
- Four days after Williams was transferred, Landgraf quit her job.
Procedural Posture:
- Barbara Landgraf filed a timely charge with the Equal Employment Opportunity Commission (EEOC).
- The EEOC found harassment but concluded the employer had adequately remedied the violation and issued Landgraf a right-to-sue notice.
- Landgraf filed suit against USI Film Products in the U.S. District Court, alleging sexual harassment in violation of Title VII.
- After a bench trial, the District Court found that Landgraf had been harassed but had not been constructively discharged, and dismissed her complaint because Title VII at the time provided no other remedy.
- Landgraf appealed the dismissal to the U.S. Court of Appeals for the Fifth Circuit.
- While the appeal was pending, Congress enacted the Civil Rights Act of 1991.
- The Court of Appeals affirmed the District Court's judgment, refusing to apply the new Act to Landgraf's case.
- The U.S. Supreme Court granted certiorari to decide whether the new Act's damages provisions applied to cases pending on enactment.
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Issue:
Do the provisions of the Civil Rights Act of 1991, which grant a right to a jury trial and authorize compensatory and punitive damages, apply retroactively to a Title VII case that was pending on appeal when the statute was enacted?
Opinions:
Majority - Justice Stevens
No. The provisions of the Civil Rights Act of 1991 authorizing compensatory and punitive damages and a jury trial do not apply to conduct that occurred before the Act's enactment. The Court established a two-part inquiry for determining a statute's temporal reach. First, a court must determine if Congress has expressly prescribed the statute's proper reach. Here, the text and legislative history of the 1991 Act are ambiguous and do not contain a clear directive for retroactive application. Second, if Congress has not spoken, the court must determine if the statute would have a 'retroactive effect,' which it does if it would impair rights a party possessed when he acted, increase a party's liability for past conduct, or impose new duties for completed transactions. Creating a new right to compensatory and punitive damages imposes a new disability and increases liability for past conduct. Because the right to a jury trial is tied to the claim for damages, it also does not apply.
Dissenting - Justice Blackmun
Yes. A straightforward textual analysis of the Act indicates that the damages and jury trial provisions should apply to pending cases. The Act's statement that it takes effect upon enactment '[e]xcept as otherwise specifically provided' implies retroactivity for all sections not specifically exempted. Sections 402(b) and 109(c), which explicitly provide for prospective application in limited circumstances, would be redundant if the entire Act were prospective. Furthermore, the presumption against retroactivity should not apply to remedial legislation like this, which does not proscribe previously legal conduct but merely expands the remedies for conduct that has been illegal for decades. There is no injustice in holding an employer responsible for injuries caused by conduct that was already unlawful.
Concurring - Justice Scalia
No. The presumption against retroactivity is a firm rule that can only be overcome by a clear statement in the statutory text itself, not by ambiguous legislative history or negative inferences. The phrase 'shall take effect upon enactment' is presumed to mean prospective application. The Court's analysis correctly reaches this result but errs by giving any credence to the competing presumption from Bradley v. School Bd. of Richmond. The proper test for retroactivity is not about 'vested rights' or a substance/procedure distinction, but about identifying the relevant activity the statute regulates; here, the statute regulates primary conduct, so the date of that conduct is the controlling event.
Analysis:
This case resolves the tension between two competing lines of precedent on statutory retroactivity (Bradley and Bowen). The Court establishes the presumption against retroactivity as the default rule, clarifying that a new statute will not apply to pre-enactment conduct if it imposes new substantive liabilities. This decision provides a more stable and predictable framework for courts analyzing the temporal scope of federal statutes that are silent on the issue. It reinforces the principle of fair notice, ensuring that parties are judged by the law that was in effect at the time of their conduct unless Congress makes its contrary intent unmistakably clear.
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