Delaware State College v. Ricks

Columbus Ricks (plaintiff), a Black man from Liberia, was an untenured faculty member at Delaware State College (the college) (defendant). On March 13, 1974, the College Board of Trustees (the trustees) formally voted to deny tenure to Ricks. Dissatisfied with the decision, Ricks immediately filed a grievance with the trustees. On June 26, 1974, the trustees offered Ricks a terminal contract to teach one additional year. The contract stated that Ricks’s employment with the college would end on June 30, 1975. Ricks signed the contract. On September 12, 1974, the trustees notified Ricks that his grievance was denied. On April 28, 1975, Ricks filed a discrimination claim with the Equal Employment Opportunity Commission (EEOC). Subsequently, Ricks filed suit in federal court. Ricks contended that the college’s decision to deny him tenure constituted discrimination on the basis of national origin in violation of Title VII of the Civil Rights Act of 1964 (Title VII). Although Ricks claimed that the college discriminated in denying him tenure, he did not allege any facts indicating that discriminatory acts occurred on June 30, 1975, the day his employment was terminated. The district court dismissed the case, finding that Ricks did not file his claim with the EEOC in a timely manner. The court of appeals reversed. The college appealed to the United States Supreme Court.