## Facts

- Celinda Brown filed a Title VII discrimination charge with the EEOC against her former employer, Baldwin County Welcome Center.
- The EEOC issued Brown a right-to-sue notice stating she had 90 days from receipt to file a civil action in federal district court.
- Within the 90-day period, Brown filed only the right-to-sue letter with the district court and requested appointment of counsel.
- A magistrate directed Brown to submit a standard form and questionnaire for the counsel request and reminded her that a complaint must be filed within 90 days.
- Brown submitted the requested materials after the 90-day period expired.
- Brown later filed a document labeled an “amended complaint” well after 90 days from receipt of the right-to-sue notice, and the employer was served thereafter.
- The district court dismissed the action as time-barred because no Rule 8–compliant complaint was filed within 90 days.
- The Eleventh Circuit reversed, reasoning that filing the right-to-sue letter tolled the 90-day period in light of Title VII’s remedial purpose.

## Issues

1. Whether filing an EEOC right-to-sue letter, without a pleading satisfying Federal Rule of Civil Procedure 8, “commences” a Title VII action within the 90-day filing period.
2. Whether equitable tolling applies to excuse failure to file a Rule 8–compliant complaint within 90 days on these facts.

## Decision

- The Supreme Court reversed the Eleventh Circuit and reinstated the district court’s dismissal.
- A Title VII action is commenced under Rule 3 only by filing a “complaint,” and the filing must satisfy Rule 8’s requirement of a short and plain statement showing entitlement to relief.
- Filing the right-to-sue letter alone did not commence the action and did not toll the 90-day statutory period.
- Equitable tolling was denied because the record did not show diligence or other circumstances justifying tolling.

## Legal Principles

- Title VII plaintiffs must comply with the Federal Rules of Civil Procedure; Title VII does not create a special, relaxed pleading or commencement regime.
- Under Rule 3, an action is commenced by filing a complaint; under Rule 8, the complaint must state the claim’s basis in a short and plain manner.
- Statutory access-to-court deadlines set by Congress are enforced as written and are not set aside based on generalized sympathy for a litigant.
- Equitable tolling is available only in limited circumstances and generally requires diligence; a plaintiff’s lack of diligence defeats tolling absent compelling justification.

## Conclusion

The Court held that a Title VII plaintiff must file a Rule 8–compliant complaint within the 90-day period after receiving an EEOC right-to-sue notice; filing the notice itself does not commence the action or toll the deadline, and equitable tolling was unavailable due to the plaintiff’s lack of diligence.


Baldwin Cnty. Welcome Ctr. v. Brown, 466 U.S. 147 (1984)