## Facts

- John R. Novotny was an officer, director, and loan officer of Great American Federal Savings & Loan Association.
- Novotny alleged that the Association’s board acted to deny female employees equal employment opportunities.
- He claimed that after he supported the female employees at a board meeting, his employment was terminated because of that support.
- Novotny filed a charge with the EEOC under Title VII and received a right-to-sue letter.
- He then sued in federal court for damages under 42 U.S.C. § 1985(3), alleging a conspiracy to deprive him of equal protection and equal privileges and immunities.
- The alleged underlying right was Title VII § 704(a), which prohibits retaliation against an employee for opposing Title VII violations or participating in Title VII proceedings.

## Issues

1. Whether 42 U.S.C. § 1985(3) permits a damages action for a conspiracy to violate rights created solely by Title VII, including the anti-retaliation protections of Title VII § 704(a).
2. Whether allowing § 1985(3) to enforce Title VII rights would improperly bypass Title VII’s administrative process, time limits, and remedial design.

## Decision

- The Supreme Court reversed the court of appeals (6–3).
- The Court held that § 1985(3) may not be used to redress violations of Title VII.
- The case was remanded because Novotny’s § 1985(3) theory failed insofar as it depended on Title VII rights.
- The Court did not decide whether § 1985(3) generally reaches sex-based conspiracies, whether intracorporate conspiracies are covered, or whether a § 1985(3) claim could proceed if grounded on a federal right independent of Title VII.

## Legal Principles

- Section 1985(3) is a remedial statute; it creates no substantive rights and provides a cause of action only when a conspiracy violates an independently defined federal right to equal protection or equal privileges and immunities.
- Rights created by Title VII cannot serve as the predicate “federal right” for a § 1985(3) claim.
- Title VII establishes a detailed administrative and judicial scheme (EEOC charge, investigation, conciliation, and strict timing rules) that would be undermined if plaintiffs could reframe Title VII claims as § 1985(3) conspiracy actions.
- Courts should not interpret § 1985(3) to permit an end run around Congress’s procedural and remedial choices in Title VII.

## Conclusion

The Court held that a plaintiff cannot seek damages under § 1985(3) for an alleged conspiracy to violate Title VII rights, because § 1985(3) is purely remedial and using it to enforce Title VII would circumvent Title VII’s comprehensive enforcement scheme.


Great Am. Fed. Sav. & Loan Ass'n v. Novotny, 442 U.S. 366 (1979)