In an important win for employees, the U.S. Court of Appeals for the Sixth Circuit held on September 25 that an employment contract may not shorten the statute of limitations to sue under Title VII of the Civil Rights Act.
The plaintiff, Barbrie Logan, began working for MGM Grand Detroit Casino (MGM) in Michigan in 2007. As part of her job application, she agreed to a six-month limitation period to bring any lawsuit against her employer. Logan was constructively discharged seven years later and filed a Charge of Discrimination with the Equal Employment Opportunity Commission (EEOC), alleging sex discrimination and retaliation. The EEOC issued a right-to-sue letter, and in 2016, Logan sued MGM under Title VII.
Logan brought her claim within Title VII’s statutory period. Nonetheless, MGM argued that Logan’s claims were barred by the six-month statute of limitations she agreed to as part of her job application. The district court agreed and granted summary judgment for MGM.
The Sixth Circuit reversed. The unanimous panel held that Title VII’s statutory limitation period is a substantive right, and therefore not prospectively waivable by employees. Further, if employers could limit the time workers have to file Title VII claims, then state contract law would determine whether employees could waive Title VII’s statute of limitations, undermining Congress’ intent that the law is applied uniformly on a national scale.
This is an important decision for employees. Rarely do employees have the ability to negotiate such terms in employment agreements—they must either walk away from the job or take agreements that limit their statutory rights. This decision will help protect employees from employers’ efforts to circumvent anti-discrimination laws.
The full decision, Logan v. MGM Grand Detroit Casino, is available here.