Natalie Thomas v. EOTech, LLC

Summary

The Fourth Circuit held that private parties may not prospectively shorten the time an employee has to bring otherwise timely Title VII or ADEA claims because doing so would disrupt the statutes’ integrated and uniform remedial schemes. The court affirmed dismissal of the Maryland Fair Employment Practice Act claims under Maryland law, vacated summary judgment on the federal claims, and remanded for further proceedings.

Holdings

1. Parties may not prospectively render untimely a lawsuit that would otherwise be timely under Title VII or the ADEA.
2. The district court did not commit reversible error in concluding that the Limitations Agreement barred Thomas's MFEPA claims under Maryland law.

Questions Presented

1. Whether a private agreement may prospectively shorten the statutory period for bringing Title VII or ADEA claims.
2. Whether the 180-day Limitations Agreement validly shortened the period for bringing Thomas's MFEPA claims under Maryland law.
3. Whether the district court properly granted summary judgment based on the Limitations Agreement.

Disposition

other