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Edelman v. Lynchburg College, 535 U.S. 106 (2002)

Legal Research Home > United States Supreme Court > 535 U.S. > Edelman v. Lynchburg College, 535 U.S. 106 (2002)

106

OCTOBER TERM, 2001

Syllabus

EDELMAN v. LYNCHBURG COLLEGE

certiorari to the united states court of appeals for the fourth circuit

No. 00-1072. Argued January 8, 2002—Decided March 19, 2002

Title VII of the Civil Rights Act of 1964 requires that a "charge" of employment discrimination be filed with the Equal Employment Opportunity Commission "within [a specified number of] days after the alleged unlawful . . . practice occurred," § 706(e)(1), and that the charge "be in writing under oath or affirmation," § 706(b). An EEOC regulation permits an otherwise timely filer to verify a charge after the time for filing has expired. After respondent Lynchburg College denied academic tenure to petitioner Edelman, he faxed a letter to the EEOC in November 1997, claiming that the College had subjected him to gender-based, national origin, and religious discrimination. Edelman made no oath or affirmation. The EEOC advised him to file a charge within the applicable 300-day time limit and sent him a Form 5 Charge of Discrimination, which he returned 313 days after he was denied tenure. Edelman subsequently sued in a Virginia state court on various state-law claims, but later added a Title VII cause of action. The College then removed the case to federal court and moved to dismiss, claiming that Edelman's failure to file the verified Form 5 with the EEOC within the applicable filing period was a bar to subject-matter jurisdiction. Edelman replied that his November 1997 letter was a timely filed charge and that under the EEOC regulation, the Form 5 verification related back to the letter. The District Court dismissed the Title VII complaint, finding that the letter was not a "charge" under Title VII because neither Edelman nor the EEOC treated it as one. The Fourth Circuit affirmed, holding that Title VII's plain language foreclosed the relation-back regulation. The court reasoned that, because a charge requires verification and must be filed within the limitations period, it follows that a charge must be verified within that period.

Held: The EEOC's relation-back regulation is an unassailable interpretation of § 706. Pp. 112-119.

(a) There is nothing plain in reading "charge" to require an oath by definition. Title VII nowhere defines "charge." Section 706(b) merely requires that a charge be verified, without saying when; § 706(e)(1) provides that a charge must be filed within a given period, without indicating whether it must be verified when filed. Neither provision incorporates the other so as to give a definition by necessary implication.

Last modified: October 4, 2007