Murray v. Board of Educ. of City of New York
984 F. Supp. 169, 1997 WL 695572, 1997 U.S. Dist. LEXIS 17527 (1997)
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Rule of Law:
A federal court has subject matter jurisdiction over a Title VII claim not explicitly raised in an EEOC charge if the new claim is 'reasonably related' to the allegations in the charge. This relationship exists when the uncharged conduct would fall within the scope of the EEOC investigation that could reasonably be expected to grow out of the original charge.
Facts:
- Johnetta Murray, a black Hispanic woman, began working for the Board of Education of the City of New York ('the Board') in 1980.
- In September 1988, Murray was assigned to serve as Interim Acting Supervisor of Special Education at Alfred E. Smith High School.
- The Board advertised for the permanent position of Assistant Principal (AP) of Special Education, and Murray applied for it on November 27, 1989.
- On November 16, 1989, Murray was involuntarily reassigned from her position at Smith High to the Bronx Superintendent’s Office, based on accusations of insubordination and poor performance, which she denied.
- The initial screening committee for the AP position did not advance Murray's application for further consideration.
- After the initial selection process was voided for procedural irregularities, a new committee was convened, and on March 7, 1990, another candidate, Maria Reekstin, was appointed to the permanent AP position.
- On September 5, 1990, Murray filed a charge with the Equal Employment Opportunity Commission (EEOC), focusing on her November 16, 1989, involuntary reassignment and stating it 'denied me future promotional opportunities.'
Procedural Posture:
- Johnetta Murray filed a Charge of Discrimination with the Equal Employment Opportunity Commission (EEOC) on September 5, 1990.
- The EEOC investigated and issued a Determination finding no statutory violation, dismissing the charge on July 8, 1991.
- Murray filed a pro se complaint in the U.S. District Court for the Southern District of New York on September 18, 1991.
- With the assistance of counsel, Murray filed an Amended Complaint on August 17, 1994, adding claims under 42 U.S.C. §§ 1981 and 1983.
- The defendants (Board of Education, Russo, Wolff, and Weisel) moved for partial summary judgment to dismiss several of Murray's claims.
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Issue:
Does a federal court have subject matter jurisdiction over a Title VII 'failure to promote' claim that was not explicitly raised in the plaintiff's EEOC charge, where the charge focused on an involuntary transfer but contained a general allegation of being denied promotional opportunities?
Opinions:
Majority - Leisure, District Judge
Yes, the court has subject matter jurisdiction because the 'failure to promote' claim is reasonably related to the claims asserted in the EEOC charge. A court may hear claims not explicitly raised in an EEOC charge if the underlying conduct would fall within the 'scope of the EEOC investigation which can reasonably be expected to grow out of the charge of discrimination.' Although Murray's EEOC charge focused on her involuntary transfer, her failure to promote claim arose from the same nucleus of operative fact—what she perceived as a discriminatory vendetta by her superiors. The allegedly discriminatory reprimands leading to her transfer were intimately related to the hiring committee's decision not to promote her. Because these two claims are so factually intertwined, an EEOC investigation into the transfer would likely have reached the events surrounding the promotion decision, as evidenced by the fact that the EEOC's actual investigation did touch upon the hiring process. Therefore, Murray exhausted her administrative remedies, and the court has jurisdiction over her failure to promote claim.
Analysis:
This opinion provides a clear application of the Second Circuit's 'reasonably related' doctrine for Title VII administrative exhaustion. It establishes that a general, and otherwise insufficient, allegation like 'denied promotional opportunities' in an EEOC charge can serve as a jurisdictional hook for a specific failure-to-promote claim if it is factually intertwined with the primary allegations. This decision reinforces a liberal 'loose pleading' standard for EEOC charges, prioritizing the notice function of the charge over technical precision, and prevents defendants from defeating claims on procedural grounds when the unpled claim stems from the same alleged discriminatory animus as the pled claim. It guides future courts to look beyond the four corners of the EEOC charge to the underlying factual circumstances and the reasonable scope of a resulting investigation.
