Arbaugh v. Y & H Corp., 546 U.S. 500 (2006)
Primary Holding
The numerical threshold of having "fifteen or more employees" in Title VII's definition of "employer" does not affect federal-court subject-matter jurisdiction but instead relates to the substantive adequacy of a Title VII claim for relief, and thus cannot be raised as a defense late in the litigation.
In the case of Arbaugh v. Y & H Corp., a woman named Jenifer Arbaugh sued her former employer for sexual harassment, but the company later claimed it didn't have enough employees to be sued under federal law. The Supreme Court decided that the rule about needing at least fifteen employees is not about whether the court can hear the case, but rather about whether the claim is valid. This ruling protects consumers by ensuring that employers can't wait until a case is almost over to argue they aren't covered by the law, which helps people hold companies accountable for discrimination. This case is relevant if someone is considering a lawsuit against an employer and wants to know if the employer meets the legal requirements to be sued under federal discrimination laws.
AI-generated plain-language summary to help you understand this case
In the case of Arbaugh v. Y & H Corp., Jenifer Arbaugh, the petitioner, filed a Title VII action against her former employer, Y&H Corporation, alleging sexual harassment. The dispute arose after a jury trial in which Arbaugh was awarded $40,000 in damages. Following the trial, Y&H Corporation moved to dismiss the case, claiming for the first time that it had fewer than 15 employees and thus was not subject to Title VII, which defines an "employer" as one with 15 or more employees. This motion was made two weeks after the jury verdict and judgment were entered. The procedural history of the case began in the federal district court, where Arbaugh's lawsuit was initially heard. After the jury's verdict, Y&H's late assertion regarding its employee count prompted the trial court to consider the motion to dismiss. The court, despite recognizing the unfairness of granting the motion, felt compelled to dismiss the case, believing that the employee-numerosity requirement was jurisdictional. Arbaugh subsequently appealed the decision, leading to the case being brought before the United States Supreme Court. The relevant background context involves the interpretation of Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination based on sex, among other factors. The Act includes a jurisdictional provision that allows federal courts to hear cases brought under its authority, but it also contains a specific definition of "employer" that limits its application to those with a minimum number of employees. The Supreme Court was tasked with determining whether this employee threshold affected federal subject-matter jurisdiction or was merely a substantive element of a Title VII claim.
Whether the numerical qualification in Title VII's definition of "employer," which requires having "fifteen or more employees," affects federal-court subject-matter jurisdiction or delineates a substantive ingredient of a Title VII claim for relief.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- January 11, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006)
Consumer WonThe anti-retaliation provision of Title VII of the Civil Rights Act of 1964 protects employees from employer actions that would dissuade a reasonable worker from making or supporting a charge of discrimination, and it is not limited to actions that affect the terms and conditions of employment or occur at the workplace.
Jackson v. Birmingham Bd. of Ed., 544 U.S. 167 (2005)
Consumer WonTitle IX of the Education Amendments of 1972 encompasses claims of retaliation against individuals who complain about sex discrimination in educational programs, thereby allowing for a private right of action in such cases.
Mohawk Industries, Inc. v. Williams, 547 U.S. 516 (2006)
Mixed OutcomeThe Supreme Court dismissed the writ of certiorari as improvidently granted, indicating that the case was not suitable for review at that time, and remanded it for further consideration in light of a related decision.
Ash v. Tyson Foods, Inc., 546 U.S. 454 (2006)
Mixed OutcomeThe use of the term "boy" by an employer in reference to African-American employees can be considered evidence of discriminatory animus, and the standard for determining whether an employer's stated nondiscriminatory reasons for hiring decisions are pretextual should not require modifiers or qualifications to be probative of bias.