Edelman v. Lynchburg College

Summary

The Court, in an opinion by Justice Souter, upheld the EEOC regulation permitting verification supplied after Title VII’s charge-filing deadline to relate back to a timely unverified charge. The statute does not require filing and verification to occur simultaneously, and the regulation accommodates lay complainants while protecting employers against having to respond to unverified allegations. The Court rejected the contention that the regulation exceeded the EEOC’s procedural rulemaking authority and found it unnecessary to decide whether Chevron deference applied. It reversed and remanded without deciding whether Edelman’s original letter constituted a charge or the significance of delayed notice to the employer. Justice Thomas concurred separately, emphasizing the EEOC’s statutory authority to issue reasonable procedural regulations consistent with the Administrative Procedure Act. Justice O’Connor, joined by Justice Scalia, concurred in the judgment, concluding that the regulation should be upheld under Chevron even though it did not reflect her preferred statutory interpretation.