National Railroad Passenger Corp. v. Morgan

On February 27, 1995, Abner Morgan (plaintiff), a Black male, filed a charge against his employer, the National Railroad Passenger Corporation (Amtrak) (defendant), with the EEOC and California’s Department of Fair Employment and Housing. Morgan alleged that he had faced harassment and harsher discipline than other Amtrak employees because of his race. Morgan also alleged the existence of a hostile work environment in which Amtrak managers made racial jokes, performed racially derogatory actions, used racial slurs, and negatively commented about Black employees’ ability to be supervisors. Some of the alleged conduct occurred within the 300-day period before the filing of Morgan’s charge, but much of the conduct occurred more than 300 days before the filing. Under 42 U.S.C. § 2000e-5(e)(1), an employee filing a charge of unlawful discrimination against an employer with the Equal Employment Opportunity Commission (EEOC) and a state regulatory agency had to file the charge within 300 days of the allegedly unlawful employment practice. The EEOC issued Morgan a right-to-sue letter, and Morgan sued Amtrak in federal district court. Amtrak moved for summary judgment, asserting that it could not be held liable for any alleged conduct that occurred outside the 300-day filing period. The district court agreed and granted partial summary judgment to Amtrak, holding that Amtrak was not liable for any conduct that occurred before May 3, 1994. The court of appeals reversed, holding that the continuing-violation doctrine allowed courts to consider conduct that was otherwise time-barred if the conduct constituted part of an ongoing unlawful employment practice. The United States granted Amtrak’s petition for certiorari.