AMTRAK v. Morgan
In AMTRAK v. Morgan, 536 U.S. 101 (2002), the U.S. Supreme Court unanimously addressed whether, and under what circumstances, a Title VII plaintiff may file suit on events that fall outside the statutory time period of 180 or 300 days for a complaint filed with the Equal Employment Opportunity Commission with respect to "the alleged unlawful employment practice" that occurred, as required by Section 2000e-5(e)(1) (1994 ed.).[1]
The United States Court of Appeals for the Ninth Circuit held that a plaintiff may sue on claims that would ordinarily be time barred so long as they either are "sufficiently related" to incidents that fall within the statutory period or are part of a systematic policy or practice of discrimination that took place, at least in part, within the limitations period.
Justice Clarence Thomas, writing for the Court, reversed in part and affirmed in part. It held that the statute precludes recovery for discrete acts of discrimination or retaliation that occur outside the statutory time period. The Court also held that consideration of the entire scope of a hostile work environment claim, including behavior alleged outside the statutory time period, is permissible for the purposes of assessing liability, so long as any act contributing to that hostile environment takes place within the statutory time period. The application of equitable doctrines, the Court held, may either limit or toll the time period within which an employee must file a charge.
Respondent Abner Morgan, Jr., had sued petitioner National Railroad Passenger Corporation (Amtrak Click for Enhanced Coverage Linking Searches) under Title VII of the Civil Rights Act of 1964, 78 Stat. 253, as amended, 42 U.S.C. § 2000e et seq. (1994 ed. and Supp.V), alleging that he had been subjected to discrete discriminatory and retaliatory acts and had experienced a racially hostile work environment throughout his employment.
