Baldwin County Welcome Center v. Brown - 466 U.S. 147 (1984)
U.S. Supreme Court
Baldwin County Welcome Center v. Brown, 466 U.S. 147 (1984)
Baldwin County Welcome Center v. Brown
Decided April 16, 1984
466 U.S. 147
After respondent filed a complaint with the Equal Employment Opportunity Commission alleging discriminatory treatment by her former employer (petitioner), she received a right-to-sue letter from the Commission in January, 1981, informing her that she could commence a civil action in Federal District Court and that, if she chose to do so, the suit must be filed within 90 days of receipt of the letter. Respondent mailed the letter to the District Court, where it was received in March. In addition, she requested appointment of counsel. In April, a Magistrate entered an order requiring that respondent's request for appointment of counsel be made by use of the court's motion form and supporting questionnaire, and reminding her that a complaint must be filed within 90 days of the issuance of the right-to-sue letter. The questionnaire was not returned until the 96th day after receipt of the right-to-sue letter, and on the next day, the Magistrate denied, as untimely, the motion for appointment of counsel, but referred to the District Judge the question whether the filing of the right-to-sue letter with the court constituted commencement of an action under the Federal Rules of Civil Procedure. The court held that respondent forfeited her right to pursue her claim under Title VII of the Civil Rights Act of 1964 because of her failure to file a proper complaint within 90 days of receipt of the right-to-sue letter, as required by the Act. The Court of Appeals reversed.
Held: There is no basis for giving Title VII actions a special status under the Federal Rules of Civil Procedure, as the Court of Appeals apparently did. Rule 3 states that an action "is commenced by filing a complaint with the court," and Rule 8(a)(2) provides that a complaint must include "a short and plain statement of the claim showing that the pleader is entitled to relief." The Court of Appeals suggested no persuasive justification for its view that the Federal Rules were to have a different meaning in, or were not to apply to, Title VII litigation. Nor is there any basis for the Court of Appeals' apparent alternative holding that the statutory 90-day period for invoking the court's jurisdiction is "tolled" by the filing of the right-to-sue letter. The record does not support application of the doctrine of equitable tolling.
Certiorari granted; 698 F.2d 1236, reversed.