Fourth Circuit issues Title VII opinion on exhaustion of administrative remedies

In CHACKO v. PATUXENT INSTITUTION, the Fourth Circuit considered whether the plaintiff exhausted his administrative remedies, and thus properly brought suit in federal district court, under Title VII of the Civil Rights Act of 1964. Prior to bringing suit, a plaintiff must file an administrative charge with the Equal Employment Opportunity Commission (EEOC). "Only those discrimination claims stated in the initial charge, those reasonably related to the original complaint, and those developed by reasonable investigation of the original complaint may be maintained in a subsequent Title VII lawsuit."

According to the Court, the plaintiff failed to exhaust his administrative remedies because his administrative charges reference different time frames, actors, and discriminatory conduct than the central factual allegations in his formal suit. According to the court, plaintiff's "centerpiece" at trial was that coworkers continually made derogatory national-origin remarks to him over the course of his twenty-year career, and that supervisors did not discipline these coworkers, laughed at their comments, and may have joined them. The administrative charges, however, alleged specific episodes of harassment. None of them mentioned coworker harassment or national-origin epithets.

Because these claims were not raised in the EEOC charge, plaintiff failed to exhaust administrative remedies.