Supreme Court of the United States
Zipes v. Trans World Airlines, Inc.
February 24, 1982455 U.S. 385
Summary
The Court held that timely filing of a discrimination charge with the EEOC is not a jurisdictional prerequisite to a Title VII suit, but instead operates like a statute of limitations subject to waiver, estoppel, and equitable tolling. Because the filing requirement did not bar the claims of the second subclass, the District Court had authority to approve the settlement and award retroactive seniority to that subclass. The judgment in No. 78-1545 was reversed, the judgment in No. 80-951 was affirmed, and the related petition in No. 78-1549 was dismissed as improvidently granted.
Holding
- Whether timely EEOC filing is jurisdictional. Timely filing of a discrimination charge with the EEOC is not a jurisdictional prerequisite to a Title VII suit. It is a requirement analogous to a statute of limitations and is subject to waiver, estoppel, and equitable tolling.
- Whether retroactive seniority could be awarded to Subclass B members and approved over the union's objection. The District Court had authority to approve the settlement and award retroactive competitive seniority to Subclass B members. The final classwide finding of discrimination supplied the predicate for relief, and the union received the process required because it intervened, presented objections, and received appropriate findings before the award was entered.
Docket 78-1545
Cited authorities
- Rule 19(a)
- CA10
- 78 Stat. 253
- 78 Stat. 253
- 81 Stat. 602
- 29 U.S.C. § 621
- Fed. R. Civ. P. 19(a)
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