Griffin v. Caleres, Inc.

Summary

The court denied Caleres, Inc.’s motion to dismiss portions of Ebony Griffin’s Title VII retaliation and employment discrimination action. The court held that allegations concerning events before Griffin’s termination were like or reasonably related to the allegations in her EEOC charge and therefore were not subject to dismissal for failure to exhaust administrative remedies.

Holdings

1. A Title VII plaintiff is deemed to have exhausted administrative remedies for judicial allegations that are like or reasonably related to the allegations timely presented in the administrative charge. Griffin's allegations concerning events leading up to her termination were related to the substance of her EEOC charge and therefore were not subject to dismissal or striking for failure to exhaust.
2. The defendant's motion for partial dismissal was denied because it provided no valid basis for striking the plaintiff's pre-termination allegations.

Questions Presented

1. Whether allegations concerning discriminatory and retaliatory events occurring before the plaintiff's July 8, 2024 termination were administratively exhausted because they were like or reasonably related to the allegations in her EEOC charge.
2. Whether those pre-termination allegations should be stricken from the amended complaint.

Disposition

other