Facts
- Colleen Donnelly filed an EEOC charge alleging sex discrimination by Yellow Freight System, Inc. under Title VII.
- The EEOC issued a right-to-sue notice advising suit must be filed within 90 days.
- Within the 90-day period, Donnelly sued in Illinois state court under the Illinois Human Rights Act based on the same alleged discrimination.
- After Yellow Freight moved to dismiss and after the 90-day period expired, Donnelly sought to amend the state-court complaint to add a Title VII claim.
- Yellow Freight removed the case to federal court and argued that Title VII claims fall within exclusive federal jurisdiction, so the state-court filing could not preserve the Title VII claim.
Issues
- Whether Congress granted federal courts exclusive jurisdiction over Title VII civil actions, thereby barring state courts from hearing Title VII claims.
- If state courts have concurrent jurisdiction, whether a timely state-court filing can serve as a proper forum for asserting a Title VII claim within the 90-day period.
Decision
- The Supreme Court affirmed the judgment for Donnelly.
- The Court held that federal courts do not have exclusive jurisdiction over Title VII actions.
- State courts have concurrent jurisdiction over Title VII claims because Title VII does not expressly confine jurisdiction to federal courts and no clear incompatibility with state adjudication was shown.
Legal Principles
- State courts are presumed competent to adjudicate federal causes of action unless Congress clearly indicates exclusive federal jurisdiction.
- To rebut concurrent jurisdiction, Congress must provide an explicit statutory directive, unmistakable implication from legislative history, or a clear incompatibility between state-court jurisdiction and federal interests.
- Title VII’s enforcement and administrative scheme does not, by itself, imply exclusive federal judicial jurisdiction absent express statutory language.
Conclusion
Title VII does not vest exclusive jurisdiction in federal courts; state courts may hear Title VII civil actions concurrently, and a plaintiff may invoke a state forum to litigate Title VII claims absent a clear congressional directive to the contrary.