Arbaugh v. Y & H Corp.
- Decided
- February 22, 2006
- Docket
- 04-944
- Status
- Published
- Jurisdiction
- Federal
Cited 6,493 timesNo negative treatment found in this library
What later courts said
- holding that Title VIPs numerosity requirement is nonjurisdietional even though it serves the important policy goal of “spar[ing] very small businesses from Title VII liability” — Reed Elsevier, Inc. v. Muchnick (2010)
- holding that an objection that a complaint failed to state a claim could not be asserted post-judgment — Greathouse v. JHS Security Inc. (2015)
- holding that Title VII’s numerosity requirement is nonjurisdictional even though it serves the important policy goal of “spar[ing] very small businesses from Title VII liability’’ — Reed Elsevier, Inc. v. Muchnick (2010)
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 Ginsburg delivered the opinion of the Court.
This case concerns the distinction between two sometimes confused or conflated concepts: federal-court “subject-matter” jurisdiction over a controversy; and the essential ingredients of a federal claim for relief. Title VII of the Civil Rights Act of 1964 makes it unlawful “for an employer . . . to discriminate,” inter alia, on the basis of sex. 42 U. S. C. § 2000e-2(a)(l). The Act’s jurisdictional provision empowers federal courts to adjudicate civil actions “brought under” Title VII. § 2000e-5(f)(3). Covering a broader field, the Judicial Code gives federal courts subject-matter jurisdiction over all civil actions “arising under” the laws of the United States. 28 U. S. C. § 1331. Title VII actions fit that description. In a provision defining 13 terms used in Title VII, 42 U. S. C. § 2000e, Congress limited the definition of “employer” to include only those having “fifteen or more employees,” §2000e(b). The question here presented is whether the numerical qualification contained in Title VII’s definition of “employer” affects federal-court subject-matter jurisdiction or, instead, delineates a substantive ingredient of a Title VII claim for relief.
The question arises in this context. Jenifer Arbaugh, plaintiff below, petitioner here, brought a Title VII action [*504] in federal court against her former employer, defendant-respondent Y&H Corporation (hereinafter Y&H), charging sexual harassment. The case was tried to a jury, which returned a verdict for Arbaugh in the total amount of $40,000. Two weeks after the trial court entered judgment on the jury verdict, Y&H moved to dismiss the entire action for want of federal subject-matter jurisdiction. For the first time in the litigation, Y&H asserted that it had fewer than 15 employees on its payroll and therefore was not amenable to suit under Title VII.
Statutes cited
- 42 U.S.C. § 2000e-2
- 28 U.S.C. § 1331
- 42 U.S.C. § 2000e
- 42 U.S.C. § 2000e-5
- 28 U.S.C. § 1367
- 28 U.S.C. § 1867
- 42 U.S.C. § 2Q
- 28 U.S.C. § 636
- 42 U.S.C. § 12111
- 28 U.S.C. § 1332
And 9 more sections cited in the full opinion.
Cite this
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006)Read the full opinion
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