## Facts

- Dortha Allen Guy, a Black employee, worked for Robbins & Myers, Inc. under a collective bargaining agreement (CBA) between the employer and International Union of Electrical, Radio & Machine Workers, AFL-CIO, Local 790.
- On October 25, 1971, the employer discharged Guy for allegedly violating the CBA leave-of-absence policy.
- Two days later, a union grievance alleging “unfair action” was filed on Guy’s behalf under the CBA procedures.
- The employer denied the grievance on November 18, 1971, concluding the discharge complied with the CBA.
- On February 10, 1972 (108 days after discharge), Guy filed an EEOC charge alleging race discrimination in her discharge.
- The EEOC later found race did not play a role, but Guy pursued a Title VII action in federal court.
- The district court dismissed as untimely under then-current Title VII § 706(d)’s 90-day filing period; the court of appeals affirmed, concluding the 1972 amendments extending the period to 180 days could not revive an already time-barred claim.

## Issues

1. For Title VII charge-filing purposes, did the “alleged unlawful employment practice” occur on the discharge date or upon completion of the CBA grievance process?
2. Does pursuing CBA grievance procedures toll Title VII’s charge-filing deadline?
3. Did the 1972 Title VII amendments extending the filing period from 90 to 180 days apply to a charge filed before the amendments’ effective date but pending thereafter, and could that extension render the charge timely?

## Decision

- The Supreme Court reversed and remanded in a unanimous decision.
- The Court held the alleged unlawful employment practice occurred on the date of discharge, not when the grievance procedure ended.
- The Court held the use of CBA grievance procedures does not toll Title VII’s charge-filing period.
- The Court held the 1972 amendments’ 180-day filing period applied to Guy’s EEOC charge, making it timely because it was filed within 180 days of discharge.

## Legal Principles

- In a Title VII discharge claim, the limitations period generally runs from the date of discharge as the alleged unlawful employment practice.
- Title VII remedies are independent of contractual grievance or arbitration remedies; pursuing CBA procedures does not suspend or toll Title VII charge-filing deadlines.
- Where Congress expressly provides that an amended limitations period applies to charges pending at enactment and to charges filed thereafter, the extended period governs even if the claim would have been untimely under the prior period.

## Conclusion

The Court held that Title VII’s charge-filing clock in a discriminatory-discharge case runs from the discharge date and is not tolled by CBA grievance proceedings, and it applied the 1972 amendments’ 180-day filing period to deem the employee’s EEOC charge timely, requiring further proceedings on the merits.


Int’l Union of Elec., Radio & Mach. Workers, AFL-CIO, Loc. 790 v. Robbins & Myers, Inc., 429 U.S. 229 (1976)