National Railroad Passenger Corp. v. Morgan
E846869
National Railroad Passenger Corp. v. Morgan is a 2002 U.S. Supreme Court decision that clarified the time limits for filing employment discrimination claims, distinguishing between discrete acts and continuing violations under Title VII.
Statements (43)
| Predicate | Object |
|---|---|
| instanceOf |
Title VII case
ⓘ
United States Supreme Court case ⓘ employment discrimination case ⓘ |
| appliesTo | Title VII charge-filing requirements with the EEOC ⓘ |
| areaOfLaw |
civil rights law
ⓘ
labor and employment law ⓘ |
| citation | 536 U.S. 101 ⓘ |
| clarifiedConcept |
discrete discriminatory acts
ⓘ
hostile work environment as a single unlawful employment practice ⓘ limits of the continuing violation doctrine under Title VII ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 2002-06-10 ⓘ |
| decisionType | majority opinion ⓘ |
| docketNumber | 00-1614 ⓘ |
| filingDeadlineClarified | 180-day or 300-day charge-filing period under Title VII ⓘ |
| holding |
A hostile work environment claim is composed of a series of separate acts that collectively constitute one unlawful employment practice.
ⓘ
As long as one act contributing to a hostile work environment occurs within the filing period, the entire time period of the hostile environment may be considered for liability. ⓘ Discrete discriminatory acts are not actionable if time-barred, even when related to acts alleged in timely filed charges. ⓘ Each discrete discriminatory act starts a new clock for filing charges under Title VII. ⓘ |
| impact |
Guides courts in distinguishing between discrete acts and hostile work environment claims.
ⓘ
Narrowed use of the continuing violation doctrine for discrete employment actions. ⓘ |
| issue |
How the filing period applies to hostile work environment claims under Title VII.
ⓘ
Whether the continuing violation doctrine allows recovery for discrete discriminatory acts occurring outside the statutory filing period. ⓘ |
| jurisdiction | United States federal law ⓘ |
| language | English ⓘ |
| legalSubject |
Title VII of the Civil Rights Act of 1964
NERFINISHED
ⓘ
continuing violation doctrine ⓘ employment discrimination ⓘ hostile work environment ⓘ statute of limitations ⓘ |
| majorityOpinionBy | Justice Clarence Thomas NERFINISHED ⓘ |
| petitioner | National Railroad Passenger Corporation NERFINISHED ⓘ |
| relatedConcept |
time-barred claims
ⓘ
unlawful employment practice ⓘ |
| respondent | Abner Morgan, Jr. NERFINISHED ⓘ |
| separateOpinionBy |
Justice Anthony M. Kennedy
NERFINISHED
ⓘ
Justice David H. Souter NERFINISHED ⓘ Justice Sandra Day O'Connor NERFINISHED ⓘ Justice Stephen G. Breyer NERFINISHED ⓘ |
| statuteInterpreted |
42 U.S.C. § 2000e-5(e)(1)
ⓘ
Title VII of the Civil Rights Act of 1964 NERFINISHED ⓘ |
| vote | 5-4 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.
Ledbetter v. Goodyear Tire & Rubber Co.
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precedentCited
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National Railroad Passenger Corp. v. Morgan
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