Law School Case Brief
Robinson v. Shell Oil Co. - 519 U.S. 337, 117 S. Ct. 843 (1997)
The plainness or ambiguity of statutory language is determined by reference to the language itself, the specific context in which that language is used, and the broader context of the statute as a whole.
Plaintiff A former employee, shortly after being discharged from his employment by defendant Shell Oil Company ("Shell"), plaintiff Charles T. Robinson, Sr., filed a charge against Shell with the Equal Employment Opportunity Commission ("EEOC"), alleging that he had been discharged because of his race. While that charge was pending, he applied for a job with another company, which contacted Shell for an employment reference. Alleging that Shell gave a negative reference in retaliation for his having filed the EEOC charge, Robinson filed an action in district court against Shell under § 704(a) of Title VII of the Civil Rights Act of 1964, (42 U.S.C.S. § 2000e-3(a)), which made it unlawful "for an employer to discriminate against his employees or applicants for employment" who availed themselves of Title VII's protections or assisted others in so doing. On Shell's motion, the district court dismissed the action, holding that § 704(a) did not apply to former employees. On appeal, the court of appeals affirmed. Shell was granted a writ of certiorari.
Were former employees such as Robinson covered by the provision on retaliatory discrimination under §704(a) of Title VII?
The Supreme Court of the United States United States reversed the court of appeals' decision. The Court held that considering the statutory language, its specific context, and the statute's broader context, the term "employees" as used in § 704(a) was ambiguous. The Court resolved the ambiguity by reference to other sections in the statute. It concluded that it was more consistent to include former employees within the scope of "employees" protected by § 704(a).
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