Trent v. Allegheny Airlines, Inc.

Summary

The court addresses Title VII claims alleging race and sex discrimination by Allegheny Airlines and a labor union. It holds that the allegations sufficiently pleaded continuing discrimination and that the union was effectively identified for purposes of EEOC exhaustion, but dismisses the complaint without prejudice because the plaintiffs did not allege or demonstrate exhaustion of the Pennsylvania state administrative remedy.

Holdings

1. The supporting affidavit and complaint adequately alleged a continuing discriminatory system, so the plaintiffs sufficiently pleaded that the EEOC charges were filed within the applicable 300-day period. The EEOC's contrary jurisdictional determination did not control the federal court's jurisdiction.
2. The Union was a proper defendant even though it was not expressly named in the EEOC charge because the factual allegations reasonably identified and implicated the Union and should have prompted an EEOC investigation of its role.
3. The complaint had to be dismissed without prejudice because it neither alleged exhaustion of the Pennsylvania Human Relations Commission remedy nor included documents showing that the charges had been filed with or deferred to the state agency.

Questions Presented

1. Whether the EEOC charges were timely when the supporting affidavit alleged a continuing pattern of discrimination involving past acts and present effects.
2. Whether the federal court could hear the Title VII claim against the Union even though the Union was not expressly named as a respondent in the EEOC charge or right-to-sue notice.
3. Whether the complaint adequately established exhaustion or deferral of Pennsylvania's state administrative remedy before the EEOC filing.

Disposition

dismissed