## Facts

- Four Black employees at Crown Zellerbach’s Bogalusa, Louisiana plant sued Crown and two local unions alleging racially discriminatory employment practices.
- Only one employee (Hill) filed a timely administrative charge with the EEOC under Title VII before suit.
- The four employees filed a Rule 23 Title VII action seeking injunctive relief on behalf of themselves and all present and prospective Black employees at the plant.
- The district court allowed a class action but limited the class to Black employees who had filed their own EEOC charges.
- The district court dismissed three named plaintiffs (Oatis, Johnson, and Young) because they had not individually filed EEOC charges.
- The EEOC (through the Attorney General) intervened in the district court proceedings.

## Issues

1. Whether a Title VII class action under § 706(e) may include class members and named plaintiffs who did not personally file EEOC charges, when one plaintiff filed a timely charge addressing the alleged discriminatory practices.

## Decision

- The Fifth Circuit reversed the dismissals of Oatis, Johnson, and Young and held the class was improperly restricted.
- The court held that class membership in a Title VII action is not limited to persons who individually filed EEOC charges.
- A single properly filed EEOC charge can satisfy the administrative prerequisite for similarly situated employees challenging the same alleged discriminatory practices.
- The case was remanded for further proceedings consistent with the ruling, including application of ordinary Rule 23 requirements.

## Legal Principles

- Title VII suits may proceed as Rule 23 class actions when the challenged conduct is appropriately addressed on a classwide basis.
- The EEOC charge requirement functions primarily to give notice and permit conciliation; it is not a requirement that every affected employee file duplicative charges when the same practices are at issue.
- When one employee timely files an EEOC charge that fairly encompasses a common discriminatory pattern or practice, similarly situated employees may participate in a resulting class action without filing separate charges.
- Restricting a Title VII class to administrative filers adds a limitation not compelled by the statutory scheme and is inconsistent with efficient, classwide enforcement against common discriminatory practices.

## Conclusion

The Fifth Circuit held that one employee’s timely EEOC charge can serve as the administrative predicate for a Title VII class action challenging the same alleged discriminatory practices, so the district court erred by limiting the class to EEOC filers and dismissing non-filing named plaintiffs.


Oatis v. Crown Zellerbach Corp., 398 F.2d 496 (5th Cir. 1968)