## Facts

- Abner J. Morgan, Jr., a Black male employee of National Railroad Passenger Corporation (Amtrak), alleged race discrimination, retaliation, and a racially hostile work environment during his employment.
- Morgan filed an administrative charge with the EEOC (cross-filed with California’s fair-employment agency) on February 27, 1995.
- Some alleged discriminatory and retaliatory actions occurred within the 300-day charge-filing period; many other alleged actions occurred earlier.
- The district court granted partial summary judgment for Amtrak, holding it could not be liable for acts outside the 300-day period.
- The Ninth Circuit reversed, allowing otherwise time-barred claims if they were sufficiently related to timely incidents or part of an ongoing discriminatory policy or practice.
- The Supreme Court reviewed how Title VII’s 180/300-day charge-filing rule applies to discrete acts versus hostile work environment claims.

## Issues

1. Whether Title VII permits recovery for discrete discriminatory or retaliatory acts outside the 180/300-day charge-filing period when related to timely acts (a continuing-violation theory).
2. Whether a hostile work environment claim may include acts outside the filing period if at least one contributing act occurred within the period and the acts form the same unlawful employment practice.
3. Whether equitable doctrines may toll or limit Title VII’s charge-filing deadlines.

## Decision

- The Court (Justice Thomas) affirmed in part and reversed in part the Ninth Circuit.
- Discrete discriminatory or retaliatory acts are separately actionable and must each be the subject of a timely EEOC charge; time-barred discrete acts are not actionable even if related to timely acts.
- A hostile work environment claim is timely if at least one act contributing to the hostile environment occurred within the filing period; earlier acts that are part of the same hostile environment may be considered for liability.
- Courts remain able to apply equitable tolling, estoppel, and waiver, but such doctrines apply sparingly.
- Time-barred discrete acts may still be used as relevant background evidence regarding timely claims.

## Legal Principles

- Title VII requires a charge to be filed within 180 days (or 300 days in deferral jurisdictions) after an unlawful employment practice occurred.
- Each discrete employment action (e.g., termination, failure to promote, denial of transfer, refusal to hire, discrete discipline) triggers its own limitations period and is independently subject to the timely charge requirement.
- The continuing-violation approach cannot revive liability for untimely discrete acts merely because they are related to timely acts.
- A hostile work environment consists of repeated conduct that collectively constitutes a single unlawful employment practice; if any contributing act is timely, the claim may include the full series of related acts.
- Equitable doctrines may toll or limit the filing period, but they do not displace the statutory rule and are applied narrowly.

## Conclusion

Title VII’s charge-filing deadlines bar liability for discrete discriminatory or retaliatory acts that occurred outside the 180/300-day period, even if connected to timely events, while hostile work environment claims may reach earlier conduct when at least one contributing act is timely and all acts are part of the same unlawful employment practice.


Nat'l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (2002)