Howell v. Department of the Army

975 F. Supp. 1293, 1997 U.S. Dist. LEXIS 12982, 1997 WL 533485
CourtDistrict Court, M.D. Alabama
DecidedJanuary 30, 1997
DocketCivil Action 96-T-261-S
StatusPublished
Cited by11 cases

This text of 975 F. Supp. 1293 (Howell v. Department of the Army) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Howell v. Department of the Army, 975 F. Supp. 1293, 1997 U.S. Dist. LEXIS 12982, 1997 WL 533485 (M.D. Ala. 1997).

Opinion

MYRON H. THOMPSON, Chief Judge.

In this lawsuit, plaintiff James F. Howell, a white federal employee working for the Department of the Army at Fort Rucker, Alabama, charges that he had suffered employment discrimination on the basis of his race, in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.A. §§ 1981a, 2000e through 2000e-17, when he was passed over for promotion in 1984, and again in 1991, in favor of an allegedly less-experienced and less-qualified black employee. He further charges that the Army failed *1296 to comply with the terms of a written negotiated settlement agreement (“NSA”) entered into by the parties. 1 Howell names as defendants the Department of the Army and its Secretary. He seeks to invoke the court’s federal-question jurisdiction, 28 U.S.C.A. § 1331, and jurisdiction under the general civil rights statute, 28 U.S.C.A. § 1343. 2

This lawsuit is now before the court on defendants’ motion to dismiss or, in the alternative, for summary judgment. For the reasons that follow, the court concludes that the defendants’ motion should be granted.

I. MOTION TO DISMISS AND SUMMARY JUDGMENT

Defendants rest their motion to dismiss or, in the alternative, motion for summary judgment on the grounds that Howell has no cause of action, because his administrative 'complaint was time-barred for missing regulatory filing deadlines, and that this court has no subject-matter jurisdiction to review the EEOC’s final decision regarding an alleged breach by the Department of the Army of an NSA.

A number of courts regard regulatory deadlines applying to federal employee lawsuits against the government as akin to statutes of limitations, rather than jurisdictional requirements. See, e.g., National Cement Co. v. Federal Mine Safety and Health Review Comm’n, 27 F.3d 526, 530 (11th Cir.1994); Fouche v. Jekyll Island-State Park Auth., 713 F.2d 1518, 1525 (11th Cir.1983) (“[A]ll Title VII procedural requirements to suit are henceforth to be viewed as conditions precedent to suit rather than as jurisdictional requirements.”); Johnson v. Runyon, 47 F.3d 911, 917 (7th Cir.1995); Bohac v. West, 85 F.3d 306, 311 (7th Cir.1996); Barrow v. New Orleans S.S. Ass’n, 932 F.2d 473, 476-77 (5th Cir.1991) (“If an EEOC charge is untimely filed, a suit based upon the untimely charge should be dismissed.”).

This approach has two practical and procedural consequences. First, failure to meet a filing deadline constitutes failure to state a claim for purposes of a motion to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure. See Oaxaca v. Roscoe, 641 F.2d 386, 391 (5th Cir. April 3, 1981) 3 ; Thompson v. West, 883 F.Supp. 1502, 1507 (M.D.Ala.1995). Second, as with statutes of limitations in general, equitable tolling applies in certain instances to excuse failures to timely file. Mosley v. Pena, 100 F.3d 1515, 1517 (10th Cir.1996); Van Zant v. ELM Royal Dutch Airlines, 80 F.3d 708, 712 (2d Cir.1996); 29 C.F.R. § 1614.604(c) (“The time limits in this part are subject to waiver, estoppel and equitable tolling.”). Of course, “A complaining party in a Title VII case bears the burden of providing the justification for application of equitable tolling principles.” Wilson v. Secretary, Department of Veterans Affairs, 65 F.3d 402, 404 (5th Cir.1995).

At least one court has recently held that meeting all administrative filing deadlines is a jurisdictional requirement for eventually filing suit in federal court, and that failure to meet all deadlines constitutes failure to exhaust administrative remedies, resulting in no waiver of sovereign immunity under Title VII, and a corresponding lack of subject-matter jurisdiction under Rule 12(b)(1), rather than Rule 12(b)(6), of the Federal Rules of Civil Procedure. Dillard v. Runyon, 928 F.Supp. 1316, 1322-23 (S.D.N.Y.1996) (“A federal employee’s suit after failure to avail herself of her administrative remedies ... in a timely fashion, does not trigger the waiver of sovereign immunity and deprives a federal court of subject-matter jurisdiction to hear that employee’s [Title VII] claim.”).

*1297 However, the Dillard court’s approach produces a distinction without a difference, for two reasons. First, and admittedly, a court can look at depositions, affidavits and other documents to examine the basis of its own subject-matter jurisdiction under Rule 12(b)(1). 4 However, given the same supporting evidence, a court may choose to convert a Rule 12(b)(6) motion to dismiss into a motion for summary judgment under Rule 56 of the Federal Rules of Civil Procedure, as discussed below, thereby yielding a judgment about the propriety of allowing the case to go forward based on exactly the same evidence. Second, interpreting Irwin v. Department of Veterans Affairs, 498 U.S. 89, 111 S.Ct. 453, 112 L.Ed.2d 435 (1990), the Dillard court demonstrated that, even if failure to timely file is treated as a jurisdictional bar, the “jurisdictional nature of the deadlines and the possibility that they may be equitably tolled are not at all inconsistent,” id. at 1324, which brought it to the same result reached by courts treating the time limits as more akin to statutes of limitations. In other words, in this context, analysis of subject-matter jurisdiction and analysis of whether a cause of action is stated for which the court can grant relief converge. Cf. McGinty v. United States Dep’t of the Army, 900 F.2d 1114, 1118 (7th Cir.1990) (“We need not decide whether [case law] would require the ADEA administrative deadlines to be treated like statutes of limitations rather than jurisdictional prerequisites because McGinty’s complaint must be dismissed under either analysis.”).

Both sides in this action submitted documents outside the pleadings to support their respective positions.

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Cite This Page — Counsel Stack

Bluebook (online)
975 F. Supp. 1293, 1997 U.S. Dist. LEXIS 12982, 1997 WL 533485, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howell-v-department-of-the-army-almd-1997.