Yellow Freight Sys. v. Donnelly - 494 U.S. 820, 110 S. Ct. 1566 (1990)

Rule:

Unlike a number of statutes in which Congress unequivocally stated that the jurisdiction of the federal courts is exclusive, Title VII of the Civil Rights Act of 1964 42, U.S.C.S. § 2000e et seq., contains no language that expressly confines jurisdiction to federal courts or ousts state courts of their presumptive jurisdiction. The omission of any such provision is strong, and arguably sufficient, evidence that Congress had no such intent. The states and federal government share concurrent jurisdiction over Title VII claims.

Facts:

Respondent employee was a qualified dockworker, who applied for work at the employer's facility. The company had no vacancies, but assured her that she would be the first person hired when the situation changed, however, petitioner hired numerous men in the meantime. Respondent filed an action in state court. Petitioner removed the case to federal court and moved to dismiss an amended complaint. Petitioner argued that the original filing in the state court could not toll the 90-day limitation period because the state court had no jurisdiction over a Title VII claim. The district court rejected the jurisdictional argument and, after a trial on the merits, entered judgment for respondent. The court of appeals affirmed. Petitioner employer sought review. 

Issue:

Did the state court lack jurisdiction over civil actions brought under Title VII? 

Answer:

No.

Conclusion:

On certiorari, the United States Supreme Court affirmed the lower courts’ decisions. The Court held that federal courts did not have exclusive jurisdiction over civil actions brought under Title VII, because the text of Title VII contained no language that expressly confined jurisdiction to federal courts or ousted state courts of their presumptive jurisdiction. Moreover, the legislative history of Title VII--which contained a number of passages indicating that most legislators, judges, and administrators who participated in the legislative process that produced Title VII fully expected that all Title VII cases would be tried in federal court--was not an adequate substitute for a legislative decision to overcome such presumption. There was no incompatibility between the procedures provided in Title VII and state court jurisdiction over Title VII claims, and there was no reason to question the presumption that state courts were just as able as federal courts to adjudicate Title VII claims.