Day v. Patapsco & Back Rivers Railroad

504 F. Supp. 1301, 25 Fair Empl. Prac. Cas. (BNA) 1573, 1981 U.S. Dist. LEXIS 10311
CourtDistrict Court, D. Maryland
DecidedJanuary 15, 1981
DocketCiv. Y-76-1484
StatusPublished
Cited by8 cases

This text of 504 F. Supp. 1301 (Day v. Patapsco & Back Rivers Railroad) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Day v. Patapsco & Back Rivers Railroad, 504 F. Supp. 1301, 25 Fair Empl. Prac. Cas. (BNA) 1573, 1981 U.S. Dist. LEXIS 10311 (D. Md. 1981).

Opinion

JOSEPH H. YOUNG, District Judge.

MEMORANDUM OPINION AND ORDER

Plaintiffs, 1 present or past employees of defendant Patapsco & Back Rivers Railroad Company [Patapsco], and present or past members of defendant United Steelworkers of America [Steelworkers] through defendant Local 2819 or defendant Local 5054, seek legal and equitable relief on account of numerous alleged violations of 42 U.S.C. § 1981 and 42 U.S.C. § 2000e et seq. (Title VII). All of the plaintiffs are black. At a pre-trial conference on November 10, 1980, many of plaintiffs’ claims were either dismissed or voluntarily abandoned, primarily on limitations grounds. Part One of this Opinion will deal with the actions taken at this pre-trial conference. The remaining claims proceeded to trial in early December; Part Two of this Opinion resolves those remaining claims.

By way of introduction, the Patapsco & Back Rivers Railroad Company is one of six (6) common carrier railroads which are wholly-owned subsidiaries of the Bethlehem Steel Corporation. Patapsco’s plant is divided into five separate departments: Maintenance-of-Way, Maintenance-of-Equipment, Locomotive, Clerical, and Transportation. Pursuant to a series of collective bargaining agreements entered into between Patapsco and Steelworkers, the first of which took effect in 1943 (Defendant Patapsco Exhibit # 66), a unit system of seniority has been in existence at Patapsco which governs promotions, demotions, layoffs, recalls, and transfers. Each department at Patapsco constitutes a separate seniority unit; indeed, certain departments contain more than one unit depending upon the number of crafts existing within the specific department. It is uncontroverted that this unit seniority system, on its face, applies equally to all races.

The six individual plaintiffs work, or worked, primarily as trackmen in the Maintenance-of-Way department. Since 1943, Maintenance-of-Way has been represented by Steelworkers Local 2819. The remaining *1304 departments are represented by Steelworkers Local 5054. The racial composition of those departments represented by Local 5054 is predominantly white, whereas the Maintenance-of-Way department is primarily black. Evidence adduced at trial indicates that Maintenance-of-Way was entirely black until December, 1967.

Part One: The November 10 Pre-Trial Conference

On October 24, 1980, defendant Patapsco filed a Motion for Partial Summary Judgment which was considered at a pre-trial conference on November 10. Patapsco’s Motion was premised upon two basic theories, limitations and exhaustion. Plaintiffs did not contest Patapsco’s assertion that a three year statute of limitations applies to actions pursued under 42 U.S.C. § 1981, see Linder v. Litton Systems, Inc., 81 F.R.D. 14, 17 (D.Md.1978); Hoggs v. Bethlehem Steel Corp., Civil Action No. Y-77-1193, Memorandum and Order at 2 (D.Md. October 25, 1979); nor did they contest the settled principle that the limitations period under Title VII is either 180 or 300 days prior to the plaintiffs’ initial filing of a discrimination complaint, depending upon whether the initial complaint was filed with a federal (180) or state (300) agency. 42 U.S.C. § 2000e-5(e); United Air Lines v. Evans, 431 U.S. 553, 558, 97 S.Ct. 1885, 1889, 52 L.Ed.2d 571 (1977). Plaintiffs did, however, argue that the doctrine of continuing discrimination operated to resurrect many otherwise untimely claims. Before discussing the individual claims, it is thus necessary to briefly review the continuing discrimination doctrine.

Simply put, the doctrine of continuing discrimination suggests that pre-limitations period acts may be sued upon at anytime, so long as the effects of those past discriminatory acts are being felt at the time of suit. The Supreme Court has gone far in recent years towards eliminating this doctrine. In United Air Lines v. Evans, supra, the Supreme Court expressly rejected a claim of continuing discrimination even though it was conceded that the plaintiff was suffering from present effects, saying:

the emphasis should not be placed on mere continuity; the critical question is whether any present violation exists.

Id. at 558, 97 S.Ct. at 1889. The Court went on to note that a past discriminatory act should, for legal purposes, be treated as “merely an unfortunate event in history which has no present legal consequences.” Id. The reason for this narrow interpretation of the continuing discrimination doctrine is apparent — to construe too loosely “continuing discrimination” would undermine the theory underlying the statute of limitations. Olson v. Rembrandt Printing Co., 511 F.2d 1228, 1234 (8th Cir. 1975) (en banc). These teachings guided this Court’s actions at the November 10 pre-trial conference.

I. Claims Against Defendant Patapsco

At the pre-trial conference, each individual claim of each individual plaintiff was reviewed in light of the limitations principles mentioned above, with the following results:

a) Plaintiff John A. Franklin
Complaint Filed: October 1, 1976
§ 1981 Limitations Date: October 1,1973 EEOC Charges Filed: June 1, 1976 Title VII Limitations Date: December 4, 1975 (180 days pre-EEOC)

Franklin alleged discrimination in four basic areas: (1) job assignments; (2) transfers; (3) seniority; (4) layoffs. The job assignment claim was comprised of three separate subclaims. First, Franklin complained that his initial assignment to the position of trackman was discriminatory. This assignment occurred in either 1954 or 1955; hence, the claim was dismissed as untimely. Second, Franklin complained that his assignment to an all-black work unit was discriminatory. This claim was abandoned, as plaintiff conceded that the Maintenance-of-Way department had been integrated since 1967. Third, Franklin complained that he received disparate pay for work which he performed as a Laborer in the Locomotive Department in 1971. This claim was also adjudged untimely and was similarly dismissed.

*1305 Both the layoff claim and the transfer claim were equally untimely. As made clear during the November 10 conference, the former claim concerned events which concluded in April, 1973; the latter involved an incident which occurred in 1962. Under the plain dictate of Evans,

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504 F. Supp. 1301, 25 Fair Empl. Prac. Cas. (BNA) 1573, 1981 U.S. Dist. LEXIS 10311, Counsel Stack Legal Research, https://law.counselstack.com/opinion/day-v-patapsco-back-rivers-railroad-mdd-1981.