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Kay Anjelino Israel Cabassa Alicia Carranza Joann Coangelo Kathleen Deangelo Margaret Deangelo Eddie Humphrey Sheila Kelly Mark S. Kornblum Robert Laura Stephen W. Maggio Hilary Mendelson Birgitta Mendola Lois Moss Noreen Moss Arthur O'COnnell Milagros Pereira Ruth Richardson Nancy J. Simatos Ellen v. Sims Anastasios Spartos Daniel Stringer Lillian Sullivan Rosa M. Torres Anna Marie Trause v. The New York Times Company Arthur Ochs Sulzberger, Jr. New York Mailers' Union No. 6 George McDonald Itu Negotiated Pension Plan (d.c. Civil No. 92-Cv-02582) Kay Anjelino Israel Cabassa Alicia Carranza Jimmy Carroll Joann Coangelo Maureen Conroy Maureen Dolphin Kathleen Deangelo Margaret Deangelo Jackie Fogarty Eddie Humphrey Janet Khoe Sheila Kelly Dennis Knapp Mark S. Kornblum Robert Laura Stephen W. Maggio Hilary Mendelson Birgitta Mendola Lois Moss Noreen Moss Arthur O'COnnell Milagros Pereira Ronald Plakis Ruth Richardson Nancy J. Simatos Ellen v. Sims Anastasios Spartos Daniel Springer Lillian Sullivan Rosa M. Torr

Citation: 200 F.3d 73Docket: 98-6024

Court: Court of Appeals for the Third Circuit; February 21, 2000; Federal Appellate Court

Narrative Opinion Summary

The case involves a group of Hispanic and non-Hispanic former mail room employees of the New York Times Company, including both male and female appellants, who filed a lawsuit alleging employment discrimination based on sex, race, color, and national origin against the Times, its publisher, and the New York Mailers' Union No. 6. The District Court initially dismissed the amended complaint for failure to exhaust administrative remedies and lack of standing, granting summary judgment to appellees. The appellate court reversed the dismissal of several claims, holding that indirect victims of discrimination can establish standing under Title VII and NJLAD if they allege injuries traceable to unlawful actions. The court also addressed issues surrounding the timeliness of claims, ruling that NJLAD claims filed before July 23, 1993, are not time-barred due to the prospective application of a two-year statute of limitations. The court found material factual disputes related to standing, exhaustion, and timeliness, rendering summary judgment inappropriate and remanded the case for further proceedings. The dismissal of retaliation claims for lack of right to sue letters was reversed, as the alleged retaliatory acts occurred after the initial complaints, and appellants should not be penalized for EEOC inaction. The court upheld the denial of further discovery based on judicial estoppel, reinforcing the strategic choice made by appellants' counsel.

Legal Issues Addressed

Exhaustion of Administrative Remedies under Title VII

Application: The court reversed the dismissal of claims due to failure to exhaust administrative remedies, emphasizing that these procedural defenses do not impact jurisdiction but are akin to statutes of limitations.

Reasoning: The District Court incorrectly dismissed the Times' case under Rule 12(b)(1) for lack of subject matter jurisdiction based on failure to exhaust administrative remedies and timeliness.

Judicial Estoppel in Discovery Requests

Application: The court upheld the denial of further discovery based on judicial estoppel, finding the appellants' counsel's readiness for trial without additional discovery as a strategic choice.

Reasoning: The District Court's denial of the appellants' motion for further discovery was based on an affidavit from their counsel asserting readiness for trial without additional discovery.

Right to Sue Letters and Retaliation Claims

Application: The dismissal of retaliation claims for lack of right to sue letters was reversed, as the alleged retaliatory acts occurred after the initial complaints, and appellants should not be penalized for EEOC inaction.

Reasoning: Regarding retaliation claims, the District Court dismissed them for lack of right to sue letters from the EEOC; however, this dismissal is reversed because the alleged retaliatory act occurred after initial complaints were filed, making it impossible to include in those charges.

Standing under Title VII and NJLAD

Application: The court reversed the dismissal of male appellants' claims, holding that indirect victims of discrimination can establish standing if they allege injuries traceable to unlawful actions.

Reasoning: The court also reversed the District Court's dismissal of the male appellants' New Jersey Law Against Discrimination (NJLAD) claims for lack of standing, referencing New Jersey case law that allows indirect victims, such as relatives of those directly affected, to bring retaliatory discharge claims.

Summary Judgment on Title VII and NJLAD Claims

Application: The court overturned the District Court's summary judgment, citing the existence of material factual issues related to standing, timeliness, and failure to exhaust remedies.

Reasoning: The ruling is overturned due to the reinstatement of material factual issues related to failure to exhaust remedies, lack of standing, and modification of the limitations period, which were not addressed by the District Court during the summary judgment motion.

Timeliness of Discrimination Claims under NJLAD

Application: The court found that NJLAD claims filed before July 23, 1993, are not time-barred due to the prospective application of a two-year statute of limitations established in Montells.

Reasoning: Consequently, NJLAD claims filed in August 1992 are not time-barred.