Alexander v. Gardner-Denver Co.

Supreme Court of the United States · 1974 · Labor Law

415 U.S. 36 (1974)

Updated August 1, 2026

Labor Lawarbitrationstatutory claimsTitle VIIcollective bargainingcollective-bargaining agreementde novo reviewindependent statutory rights

Facts

Petitioner, a black employee, was discharged by Gardner-Denver Co. for allegedly producing too many defective or unusable parts. He filed a grievance under the collective-bargaining agreement claiming unjust discharge; no explicit racial discrimination claim appeared in the initial grievance, though he later raised racial discrimination during the grievance process and at arbitration. The collective-bargaining agreement prohibited discrimination and required final and binding arbitration of disputes arising under the agreement, with the arbitrator limited to interpreting the agreement. The arbitrator found petitioner had been discharged for just cause and did not address racial discrimination; after the EEOC found no reasonable cause and issued a right-to-sue notice, petitioner filed this Title VII action.

Issue

Whether an employee's statutory right to a trial de novo under Title VII may be foreclosed by prior submission of his claim to final arbitration under the nondiscrimination clause of a collective-bargaining agreement. More specifically, the question was whether the prior arbitral decision precluded or required judicial deference that would bar petitioner from pursuing his Title VII action in federal court.

Rule

An employee does not forfeit his private cause of action under Title VII by first pursuing a grievance to final arbitration under the nondiscrimination clause of a collective-bargaining agreement. Contractual rights under a collective-bargaining agreement and statutory rights under Title VII have legally independent origins, Title VII rights are not subject to prospective waiver, and federal courts must determine Title VII claims de novo, although an arbitral decision may be admitted as evidence and given such weight as the court deems appropriate.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Brooks worked at Lakeview Components in Toledo, Ohio, under a collective-bargaining agreement that banned sex discrimination and required final arbitration of discharge grievances. After an arbitrator upheld her firing as supported by just cause, Nina timely obtained a right-to-sue notice and filed a Title VII action alleging the discharge was motivated by sex discrimination.

What is the strongest argument against dismissing Nina's Title VII suit?

Explanation. Title VII rights are independent statutory rights, distinct from contractual rights enforced in arbitration under a collective-bargaining agreement. Once the employee satisfies Title VII's prerequisites, a prior arbitral decision neither bars suit nor divests the federal court of jurisdiction. The court must consider the Title VII claim de novo, though it may admit the award as evidence and give it appropriate weight.