## Facts

- Jessica Hoffman worked at a restaurant/steakhouse operated by R.I. Enterprises, Inc. (doing business as Ramada Inn).
- Hoffman alleged severe and pervasive sex-based harassment creating a hostile work environment.
- She filed a timely administrative charge alleging harassment directed at herself and one other identified female employee.
- The charge did not state that Hoffman was acting for other women, allege a pattern or practice affecting multiple female employees, or otherwise signal a representative or class-wide claim.
- After receiving a right-to-sue notice, Hoffman sued under Title VII and sought to certify a class of other female employees allegedly subjected to the same hostile environment.
- The court denied class certification on the ground that the administrative charge did not provide notice of potential class claims.
- Hoffman moved for reconsideration, arguing that the “single-filing rule” permitted absent class members to rely on her charge.

## Issues

1. Whether absent class members could rely on Hoffman’s timely EEOC charge under the Title VII single-filing (piggybacking) rule despite the charge’s individualized scope.
2. Whether Hoffman’s administrative charge gave adequate notice to the employer and the agency of potential class-wide claims to support class certification.
3. Whether reconsideration was warranted based on an intervening change in law, newly discovered evidence, or clear error/manifest injustice.

## Decision

- The court denied Hoffman’s motion for reconsideration.
- The court maintained its prior order denying class certification.
- The case could proceed only on Hoffman’s individual Title VII hostile-work-environment claim, not on behalf of a class.

## Legal Principles

- In a Title VII class action, at least one named plaintiff must timely exhaust administrative remedies; absent employees may sometimes rely on that charge under the single-filing rule.
- Piggybacking is generally unavailable where the administrative charge is limited to individual grievances and does not indicate widespread, systemic, or class-wide discrimination, or otherwise communicate a representative claim.
- The EEOC charge requirement serves to give the employer notice and an opportunity to conciliate and to permit agency investigation before litigation; the single-filing rule cannot be applied in a way that defeats those functions.
- Reconsideration requires an intervening change in controlling law, new evidence previously unavailable, or the need to correct clear error of law or prevent manifest injustice; reargument is insufficient.

## Conclusion

Because Hoffman’s administrative charge described harassment affecting only herself and one other identified employee and did not alert the employer or agency to broader group claims, the single-filing rule could not support class treatment; lacking any basis for reconsideration, the court left class certification denied.


Hoffman v. R.I. Enters., Inc., 50 F. Supp. 2d 393 (M.D. Pa. 1999)