Doan v. NSK Corp.
Docket: Nos. 03-1900, 03-1936
Court: Court of Appeals for the Sixth Circuit; April 30, 2004; Federal Appellate Court
Paula Doan, a Michigan resident, appeals a district court's dismissal of her civil rights action under Title VII of the Civil Rights Act of 1964 against her employer, NSK Corporation. NSK cross-appeals to preserve its rights. Both parties waived oral argument, and the panel unanimously agreed that it was unnecessary. Doan began her employment with NSK in January 1994 and entered an apprenticeship program in May 1996, which required 8000 hours of on-the-job training and coursework. She alleged sex discrimination due to NSK's decision in April 1997 to substitute two courses in place of one that was dropped, claiming male apprentices were not similarly required to take additional courses. After filing a discrimination charge with the EEOC in October 2001, which resulted in a right-to-sue letter in January 2002, the district court granted NSK's motion for summary judgment on June 10, 2003. The court determined its jurisdiction was confined to the 1997 course change referenced in Doan's EEOC charge and did not consider other alleged incidents raised during discovery. Doan's EEOC charge was filed beyond the 300-day statute of limitations, and the court found she was not entitled to equitable tolling due to a lack of due diligence in pursuing her rights. On appeal, Doan contends the district court erred regarding the limitations period and equitable tolling. The appeals court affirms the district court's judgment, emphasizing that federal jurisdiction over Title VII claims requires a timely EEOC charge and noting that the scope of jurisdiction was correctly limited to her claim regarding the course change. In states with their own anti-discrimination laws, such as Michigan, a plaintiff must file an EEOC charge within 300 days of the alleged unlawful employment practice. Doan became aware of the issue in spring 1997 but did not file her EEOC charge until October 2001, exceeding the 300-day limit by over three years. Her claims that prior informal complaints or requests for reconsideration constituted a 'continuing act of discrimination' or reset the limitations period do not hold, as they contradict established precedent. The district court correctly ruled that Doan’s EEOC charge was untimely. Filing within the time frame is a condition precedent for a Title VII lawsuit and can be subject to equitable tolling, which is to be applied sparingly and only in compelling circumstances. No such circumstances were present in this case, leading to the affirmation of the district court’s judgment.