Case law · Highest court · Federal

National Railroad Passenger Corporation v. Morgan

Decided
June 10, 2002
Docket
00-1614
Status
Published
Jurisdiction
Federal

Cited 6,600 timesSuperseded by statute (not yet verified)Possible negative treatment: superseded by statute (not yet verified) · Bonner v. Medical Board of California

What later courts said

  • recognizing that statute of limitations for Title VII claims begins to run with "each retaliatory adverse employment decision” — Bowen-Hooks v. City of New York (2014)
  • recognizing that “termination, failure to promote, denial of transfer, or refusal to hire” are easily identifiable as discrete acts — Cooper-Day v. RME Petroleum Co. (2003)
  • holding that a hostile-work-environment claim is a single "unlawful employment practice" that includes every act composing that claim, whether those acts are independently actionable or not — Green v. Brennan (2016)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

Justice Thomas delivered the opinion of the Court.

Respondent Abner Morgan, Jr., sued petitioner National Railroad Passenger Corporation (Amtrak) under Title VII of the Civil Rights Act of 1964, 78 Stat. 253, as amended, 42 U. S. C. § 2000e et seq., alleging that he had been subjected to discrete discriminatory and retaliatory acts and had experienced a racially hostile work environment throughout his employment. Section 2000e-5(e)(l) requires that a Title [*105] VII plaintiff file a charge with the Equal Employment Opportunity Commission (EEOC) either 180 or 300 days “after the alleged unlawful employment practice occurred.” We consider whether, and under what circumstances, a Title VII plaintiff may file suit on events that fall outside this statutory time period.

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. We reverse in part and affirm in part. We hold that the statute precludes recovery for discrete acts of discrimination or retaliation that occur outside the statutory time period. We also hold 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 an act contributing to that hostile environment takes place within the statutory time period. The application of equitable doctrines, however, may either limit or toll the time period within which an employee must file a charge.

Statutes cited

Cite this

National Railroad Passenger Corporation v. Morgan, 536 U.S. 101 (2002)

Read the full opinion

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