Law School Case Brief
Balas v. Huntington Ingalls Indus. - 711 F.3d 401 (4th Cir. 2013)
Federal courts lack subject matter jurisdiction over Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e, claims for which a plaintiff has failed to exhaust administrative remedies.
According to Plaintiff Karen Balas, her employer defendant Huntington Ingalls subjected her to an ongoing sexually hostile work environment that included unwanted requests from her supervisor for sex, numerous sexual comments, sexually explicit posters knowingly being allowed in her workplace, employees massaging one another, sexually offensive pictures, and unwanted touching. In her complaint, Balas alleges that she repeatedly complained of gender discrimination and a hostile work environment. She asserts that because of these complaints, she was repeatedly denied promotions and subsequently, was fired for falsifying time records. Another female employee was fired the same day for the same infraction. It is undisputed that Balas did not properly account for taking off over an hour of time.
Although Balas submitted an intake questionnaire to the Equal Employment Opportunity Commission (EEOC), which prepared a charge on her behalf, alleging sex discrimination and retaliatory termination, the EEOC later dismissed Balas's charge and issued her right to sue letter. Balas subsequently filed suit in the district court pro se, claiming discrimination, retaliation, and hostile work environment, brought under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e, as well as wrongful discharge, assault, and battery, brought under Virginia law, against defendant, the successor to her former employer. The district court denied her claims for lack of jurisdiction.
Does the federal court acquire jurisdiction over claims under Title VII of the Civil Rights Act of 1964 when the plaintiff fails to exhaust administrative remedies?
The judgment of the district court was affirmed. Any Title VII claims based on allegations included only in the employee's intake questionnaire and letters were therefore outside the jurisdiction of the federal courts. The employee's proposed amendment would have been futile because the Virginia Supreme Court had struck down Va. Code § 18.2-344 as unconstitutional, the physical contact of which Balas complained did not even begin to approach the sort of "open and gross lewdness" Va. Code § 18.2-345 prohibited, and it was legally impossible to consent to sexual assault. Finally, the employee's failure demonstrate that her alleged harasser possessed such authority as to be viewed as the one principally responsible for the decision was fatal to her retaliation claim.
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