Fort Bend County v. Davis

Lois M. Davis, a former employee of Fort Bend County, Texas, alleged religious discrimination and retaliation after she was fired for attending a church event. She filed a charge with the EEOC and later added a retaliation claim in federal court. The district court dismissed the retaliation claim because it was not specifically included in her EEOC charge. The Fifth Circuit reversed in part, holding that the charge-filing requirement was not jurisdictional. Fort Bend County appealed, arguing the defect deprived the court of jurisdiction. The Supreme Court granted certiorari to resolve whether Title VII's administrative exhaustion requirement is a jurisdictional bar or a procedural rule that can be waived. The case highlights procedural hurdles in employment discrimination lawsuits.

The Supreme Court unanimously ruled that Title VII's charge-filing requirement is not jurisdictional but a mandatory claim-processing rule. The defense that a claim was not included in an EEOC charge must be timely raised, or it is forfeited. The case was remanded for further proceedings consistent with this holding.

Whether the requirement in Title VII of the Civil Rights Act that an employee file a charge with the Equal Employment Opportunity Commission before suing in federal court is a jurisdictional prerequisite that courts must enforce sua sponte, or a non-jurisdictional claim-processing rule subject to waiver and forfeiture.

The decision reinforced the distinction between jurisdictional and non-jurisdictional rules, preventing defendants from raising procedural objections late in litigation to derail employment discrimination claims. It provided clarity and fairness for both employers and employees, ensuring that such procedural defenses are not unwaivable and promoting judicial efficiency in civil rights enforcement.