Yellow Freight System, Inc. v. Donnelly
110 S. Ct. 1566, 1990 U.S. LEXIS 2023, 108 L. Ed. 2d 834 (1990)
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Rule of Law:
State courts have concurrent jurisdiction with federal courts over civil actions brought under Title VII of the Civil Rights Act of 1964. To rebut the presumption of concurrent jurisdiction, Congress must explicitly state in the statute that federal jurisdiction is exclusive, or there must be a clear incompatibility between state-court jurisdiction and federal interests.
Facts:
- In 1982, Donnelly, a qualified dock worker, applied for a job at a Yellow Freight System, Inc. (Yellow Freight) facility.
- Yellow Freight assured Donnelly she would be the first person hired when a position became available.
- Over the next year and a half, Yellow Freight hired several men for dock worker positions but did not hire Donnelly.
- Donnelly was hired by Yellow Freight only after she filed a discrimination complaint with the Equal Employment Opportunity Commission (EEOC) in 1984.
- On March 15, 1985, the EEOC issued Donnelly a Notice of Right to Sue.
Procedural Posture:
- Donnelly filed a complaint in the Circuit Court of Cook County, Illinois (a state trial court), alleging a violation of the Illinois Human Rights Act.
- After Yellow Freight moved to dismiss, Donnelly moved to amend her complaint to add a federal Title VII claim.
- Yellow Freight removed the case to the U.S. District Court for the Northern District of Illinois.
- In federal court, Yellow Freight moved to dismiss, arguing that the state court lacked jurisdiction over the Title VII claim, rendering the initial filing invalid for tolling the statute of limitations.
- The District Court rejected the jurisdictional argument and entered judgment for Donnelly after a trial on the merits.
- The U.S. Court of Appeals for the Seventh Circuit affirmed the District Court's judgment.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue of jurisdiction.
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Issue:
Do federal courts have exclusive jurisdiction over civil actions brought under Title VII of the Civil Rights Act of 1964, thereby divesting state courts of their concurrent authority to adjudicate such claims?
Opinions:
Majority - Justice Stevens
No. State courts have concurrent jurisdiction over Title VII claims because Congress did not explicitly make federal court jurisdiction exclusive. Under the American system of dual sovereignty, there is a strong presumption that state courts are competent to adjudicate claims arising under federal law. To overcome this presumption, Congress must affirmatively divest state courts of jurisdiction through an explicit statutory directive. The text of Title VII grants jurisdiction to federal courts but contains no language that expressly confines jurisdiction to them or ousts state courts. While the legislative history may suggest an expectation that these cases would be tried in federal court, such an expectation is not a substitute for a clear legislative decision to make federal jurisdiction exclusive. Furthermore, procedural features of Title VII, such as its reference to EEOC processes or federal rules, are not incompatible with state court jurisdiction.
Analysis:
This decision solidifies the strong presumption of concurrent jurisdiction for federal statutes, placing a high burden on those arguing for exclusive federal jurisdiction. It clarifies that unless Congress explicitly uses words like 'exclusive' in a statute's jurisdictional provision, plaintiffs retain the choice to file their federal claims in state court. This increases plaintiffs' strategic options in litigation, allowing them to choose a potentially more favorable or convenient state forum. The ruling reinforces the principle that state courts are considered equally competent to interpret and apply federal law, upholding a core tenet of American federalism.
