Arbaugh v. Y & H Corp.
Supreme Court of the United States
January 11, 2006, Argued ; February 22, 2006, Decided
[*503] [**1238] [***1102] JUSTICE GINSBURG delivered the opinion of the Court.
This case concerns the distinction between two sometimes confused or conflated concepts: federal-court "subject-matter" jurisdiction over a controversy; and the essential ingredients of a federal claim for relief. [****8] Title VII of the Civil Rights Act of 1964 makes it unlawful "for an employer . . . to discriminate," inter alia, on the basis of sex. 42 U.S.C. § 2000e-2(a)(1). The Act's jurisdictional provision empowers federal courts to adjudicate civil actions "brought under" Title VII. § 2000e-5(f)(3). Covering a broader field, the Judicial Code gives federal courts subject-matter jurisdiction over all civil actions "arising under" the laws of the United States. 28 U.S.C. § 1331. Title VII actions fit that description. In a provision defining 13 terms used in Title VII, 42 U.S.C. § 2000e, Congress limited the definition of "employer" to include [***1103] only those having "fifteen or more employees," § 2000e(b). The question here presented is whether the numerical qualification contained in Title VII's definition of "employer" affects federal-court subject-matter jurisdiction or, instead, delineates a substantive ingredient of a Title VII claim for relief.
The question arises in this context. Jenifer Arbaugh, plaintiff below, petitioner here, brought a Title VII action [*504] in federal court against her former employer, defendant-respondent [****9] Y & H Corporation (hereinafter Y&H), charging sexual harassment. The case was tried to a jury, which returned a verdict for Arbaugh in the total amount of $ 40,000. Two weeks after the trial court entered judgment on the jury verdict, Y&H moved to dismiss the entire action for want of federal subject-matter jurisdiction. For the first time in the litigation, Y&H asserted that it had fewer than 15 employees on its payroll and therefore was not amenable to suit under Title VII.
Although recognizing that it was "unfair and a waste of judicial resources" to grant the motion to dismiss, App. to Pet. for Cert. 47, the trial court considered itself obliged to do so because it believed that the 15-or-more-employees requirement was jurisdictional. We reject that categorization and hold that the numerical threshold does not circumscribe federal-court subject-matter jurisdiction. Instead, the employee-numerosity requirement relates to the substantive adequacy of Arbaugh's [**1239] Title VII claim, and therefore could not be raised defensively late in the lawsuit, i.e., after Y&H had failed to assert the objection prior to the close of trial on the merits.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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546 U.S. 500 *; 126 S. Ct. 1235 **; 163 L. Ed. 2d 1097 ***; 2006 U.S. LEXIS 1819 ****; 74 U.S.L.W. 4138; 97 Fair Empl. Prac. Cas. (BNA) 737; 87 Empl. Prac. Dec. (CCH) P42,264; 19 Fla. L. Weekly Fed. S 110
JENIFER ARBAUGH, PETITIONER v. Y & H CORPORATION, DBA THE MOONLIGHT CAFE
Subsequent History: On remand at, Remanded by Arbaugh v. Y&H Corp., 446 F.3d 573, 2006 U.S. App. LEXIS 9279 (5th Cir. La., Apr. 13, 2006)
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT.
Arbaugh v. Y&H Corp., 380 F.3d 219, 2004 U.S. App. LEXIS 15842 (5th Cir. La., 2004)
Disposition: Reversed and remanded.
subject-matter, employees, employee-numerosity, threshold, merits, district court, trial court, federal court, courts, federal-court, parties, civil action, terms, subject matter jurisdiction, jurisdictional provisions, supplemental jurisdiction, federal-question, state-law
Labor & Employment Law, Title VII Discrimination, Scope & Definitions, General Overview, Business & Corporate Compliance, Employers, Civil Procedure, Subject Matter Jurisdiction, Federal Questions, Constitutional Law, Jurisdiction, Federal Questions, Jurisdictional Sources, Statutory Sources, Remedies, Supplemental Jurisdiction, Responses, Defenses, Demurrers & Objections, Motions to Dismiss, Motions to Dismiss, Failure to State Claim, Waiver & Preservation of Defenses, Diversity Jurisdiction, Trials, Jury Trials, Province of Court & Jury, Governments, Legislation, Interpretation, Jurisdiction Over Actions