## Facts

- Clarence Brown, a federal employee of the General Services Administration (GSA), alleged race discrimination based on GSA’s failure to promote him.
- Brown pursued administrative relief: GSA denied his complaint, and a Civil Service Commission complaints examiner found no discrimination (February 1973).
- GSA issued its final decision (March 1973), notified Brown of available procedures, and advised of judicial review under Title VII § 717(c) within 30 days.
- Brown did not pursue further administrative appeal; he filed suit in federal district court 42 days after receiving notice of the final agency decision.
- The complaint invoked Title VII (including § 717) and also relied on 28 U.S.C. § 1331, the Declaratory Judgment Act, and 42 U.S.C. § 1981.

## Issues

1. Whether Title VII § 717 provides the exclusive judicial remedy for federal employees’ employment-discrimination claims.
2. Whether a federal employee who misses § 717(c)’s 30-day filing period may proceed instead under § 1981, § 1331, or the Declaratory Judgment Act.
3. Whether § 717 operates as a limited waiver of sovereign immunity whose conditions must be strictly satisfied.

## Decision

- The Supreme Court affirmed dismissal of the complaint.
- The Court held that Title VII § 717 supplies the exclusive judicial remedy for discrimination in federal employment.
- Because Brown filed outside § 717(c)’s 30-day period, the action was barred.
- Brown could not avoid Title VII’s administrative scheme and filing deadline by pleading alternative statutory grounds such as § 1981 or § 1331, or by seeking declaratory relief.

## Legal Principles

- For federal employees and applicants, Title VII § 717 establishes an exclusive, comprehensive administrative-and-judicial framework for discrimination claims based on race, color, religion, sex, or national origin.
- A plaintiff must comply with § 717’s prerequisites and time limits to obtain judicial review; filing outside § 717(c)’s 30-day period bars suit.
- General jurisdictional statutes and other remedial provisions (including 28 U.S.C. § 1331, the Declaratory Judgment Act, and 42 U.S.C. § 1981) cannot be used to bypass § 717’s procedures and deadlines for federal-employment discrimination claims.
- Because the United States may be sued only to the extent it consents, the conditions Congress placed on the § 717 waiver of sovereign immunity—including the filing deadline—control.

## Conclusion

The Court concluded that Congress channeled federal-employment discrimination claims into Title VII § 717 as the sole route to judicial relief and that missing § 717(c)’s filing deadline forecloses suit, regardless of attempts to reframe the claim under other statutes.


Brown v. Gen. Servs. Admin., 425 U.S. 820 (1976)