Alexander v. Gardner-Denver Co.

Harrell Alexander (plaintiff), a Black man, was a maintenance worker for Gardner-Denver Company (defendant). In June 1968, Gardner-Denver awarded Alexander a drill-operator-trainee position. However, Gardner-Denver discharged Alexander the following year, claiming that Alexander’s work was unsatisfactory. Alexander filed a grievance against Gardner-Denver under the collective-bargaining agreement (CBA) between Gardner-Denver and Alexander’s union. Alexander claimed in the grievance that he had been unjustly discharged, but he did not allege racial discrimination. The CBA provided for a four-step grievance procedure governing disputes between Gardner-Denver and the union. If a dispute was unresolved at the end of the grievance procedure, the CBA provided that the dispute would be submitted to final and binding arbitration. During the grievance process, Alexander alleged for the first time that his discharge was prohibited by the CBA because it had been racially motivated. Gardner-Denver rejected Alexander’s claims, and the dispute went to arbitration. Before the arbitration hearing, Alexander filed a racial-discrimination charge with state civil-rights authorities, who referred the complaint to the federal Equal Employment Opportunity Commission (EEOC). At the arbitration hearing, Alexander claimed that he had filed the charge with the state civil-rights commission because he felt he could not rely on the union. The arbitrator ruled that Alexander had been discharged for just cause but did not mention Alexander’s racial-discrimination allegations. The following year, the EEOC determined that there was not reasonable cause to find a violation of Title VII of the Civil Rights Act of 1964. Alexander subsequently sued Gardner-Denver in federal district court, alleging that his discharge had been motivated by racial discrimination in violation of Title VII. The district court granted summary judgment for Gardner-Denver, finding that Alexander had voluntarily elected to pursue his grievance under the CBA and thus was precluded from bringing the Title VII suit against Gardner-Denver. The appellate court affirmed, and the United States Supreme Court granted certiorari.