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EEOC Rule That Conflicts with Statutory Time Limit Held Invalid

Description Appeals court held that the EEOC could not issue a regulation that directly conflicts with the words of Congress in a statute. Congress specified a 180 day waiting period before filing suits under Title VII of the 1964 Civil Rights Act; the EEOC regulation stated that it could waive the waiting period.

Topic Administrative Law

Key Words Statutory Authority; Invalid Regulation

C A S E S U M M A R Y

Facts On 4/10/95, Martini filed a sexual harassment charge with the EEOC against her former employer. On 5/1/95, at her request, the EEOC issued a "right-to-sue" letter authorizing her to bring a private action in federal court. Issuing the letter ended EEOC involvement in the matter without having investigated her charges. On 7/20/95, 101 days after filing the EEOC complaint, she filed suit in federal court. Her employer asked that the suit be dismissed because the statutory requirement of a 180-day waiting period for private suits to be filed for EEO violations had not been met. The trial judge refused the request; Martini won her case; the employer appealed.

Decision Reversed. Title VII of the 1964 Civil Rights Act requires complainants to wait 180 days before suing in federal court; thus requiring dismissal of the employee's untimely suit. The EEOC's regulation that allowed it to issue "early right-to-sue" letters was invalid because the statute clearly states that regardless of how EEOC rules on a complaint, suit may not be filed for at least 180 days after the complaint is filed with the EEOC. The intent of Congress is clear in the words of the statute; the EEOC cannot issue a regulation that is contrary to the words of the statute.

Citation Martini v. Federal National Mortgage Assn., 178 F.3d 1336 (D.C. Cir., 1999)

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EEOC Rule That Conflicts with Statutory Time Limit Held Invalid
Description	Appeals court held that the EEOC could not issue a regulation that directly conflicts with the words of Congress in a statute. Congress specified a 180 day waiting period before filing suits under Title VII of the 1964 Civil Rights Act; the EEOC regulation stated that it could waive the waiting period.
Topic	Administrative Law
Key Words	Statutory Authority; Invalid Regulation
C A S E S U M M A R Y
Facts	On 4/10/95, Martini filed a sexual harassment charge with the EEOC against her former employer. On 5/1/95, at her request, the EEOC issued a "right-to-sue" letter authorizing her to bring a private action in federal court. Issuing the letter ended EEOC involvement in the matter without having investigated her charges. On 7/20/95, 101 days after filing the EEOC complaint, she filed suit in federal court. Her employer asked that the suit be dismissed because the statutory requirement of a 180-day waiting period for private suits to be filed for EEO violations had not been met. The trial judge refused the request; Martini won her case; the employer appealed.
Decision	Reversed. Title VII of the 1964 Civil Rights Act requires complainants to wait 180 days before suing in federal court; thus requiring dismissal of the employee's untimely suit. The EEOC's regulation that allowed it to issue "early right-to-sue" letters was invalid because the statute clearly states that regardless of how EEOC rules on a complaint, suit may not be filed for at least 180 days after the complaint is filed with the EEOC. The intent of Congress is clear in the words of the statute; the EEOC cannot issue a regulation that is contrary to the words of the statute.
Citation	Martini v. Federal National Mortgage Assn., 178 F.3d 1336 (D.C. Cir., 1999)