Yellow Freight System, Inc. v. Donnelly

Supreme Court of the United States · 1990 · Federal Courts

Federal CourtsConcurrent jurisdictionTitle VIITitle VIIconcurrent jurisdictionexclusive federal jurisdictionstate court jurisdictionSupremacy Clause

Facts

Respondent, a qualified dock worker, applied for work at petitioner's Chicago Ridge facility in 1982 and was repeatedly told there were no vacancies, even though petitioner was hiring a number of men. She was hired only after filing a discrimination charge with the EEOC in 1984. On March 15, 1985, the EEOC issued a Notice of Right to Sue advising that suit had to be filed within 90 days. Within that period respondent filed in Illinois state court under state law, then later sought to amend the complaint to add a Title VII claim, prompting petitioner to argue that the state court lacked jurisdiction over Title VII actions.

Issue

Do federal courts have exclusive jurisdiction over civil actions brought under Title VII of the Civil Rights Act of 1964, or do state courts have concurrent jurisdiction to adjudicate such claims?

Rule

Under the system of dual sovereignty, state courts have inherent authority and are presumptively competent to adjudicate claims arising under federal law. Federal jurisdiction is exclusive only if Congress affirmatively divests state courts of their presumptively concurrent jurisdiction, which may be shown by explicit statutory language or by an incompatibility between state-court jurisdiction and federal interests sufficient to overcome the presumption.

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

Nina Patel received a federal right-to-sue notice on an employment-discrimination claim and filed her federal statutory action in a Colorado state trial court in Denver. The statute says only that "United States district courts shall have jurisdiction" over actions under the statute, and it says nothing about exclusivity or state courts.

If the employer moves to dismiss for lack of subject-matter jurisdiction, how should the court rule?

Explanation. The majority rule starts with a presumption that state courts have concurrent authority to adjudicate federal claims. A statutory grant of jurisdiction to federal district courts, without language making that jurisdiction exclusive or ousting state courts, does not overcome that presumption. So the state court may hear the claim.