Law School Case Brief
Alexander v. Gardner-Denver Co. - 415 U.S. 36, 94 S. Ct. 1011 (1974)
In submitting a grievance to arbitration, an employee seeks to vindicate his contractual right under a collective-bargaining agreement. By contrast, in filing a lawsuit under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., an employee asserts independent statutory rights accorded by Congress. The distinctly separate nature of these contractual and statutory rights is not vitiated merely because both were violated as a result of the same factual occurrence. And no inconsistency results from permitting both rights to be enforced in their respectively appropriate forums.
After Harrell Alexander, Sr., was terminated by defendant employer, Gardner-Denver Company, he initiated grievance proceedings pursuant to a collective-bargaining agreement. Alexander, an African-American, testified at an arbitration hearing that he was discharged due to racial discrimination, but the arbitrator ruled that Alexander was discharged for just cause. Alexander then sued defendant employer under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. §§ 2000e et seq. The district court granted summary judgment to defendant, which the Court of Appeals for the Tenth Circuit affirmed, holding that Alexander was precluded from litigating the Title VII claim due to the arbitrator's ruling against him. The United States Supreme Court granted certiorari review.
Was a former employee precluded from litigating his Title VII claim alleging racial discrimination due to the arbitrator’s ruling against him?
The United States Supreme Court held that Alexander, in submitting his grievance to arbitration, was seeking to vindicate his contractual rights under the collective-bargaining agreement, and therefore, was not precluded from asserting his independent statutory rights under Title VII. According to the Court, Title VII was designed to supplement, rather than supplant, existing laws and institutions relating to employment discrimination, as may be inferred from the legislative history of Title VII, which manifested a congressional intent to allow an individual to pursue rights under Title VII and other applicable state and federal statutes. The Court averred that by merely resorting to the arbitral forum petitioner did not waive his cause of action under Title VII; the rights conferred thereby cannot be prospectively waived and form no part of the collective-bargaining process. Moreover, the Supreme Court rejected respondent's suggestion that the courts had to defer to the arbitrator's decision, and held that a federal court should consider a claim under Title VII de novo, while according such weight to an arbitral decision as the court deemed proper.
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