EEOC v. Arabian American Oil Co. (Aramco), 499 U.S. 244 (1991)
EEOC v. Arabian American Oil Co., commonly called Aramco, is a foundational Supreme Court decision on the presumption against extraterritoriality and its application to federal anti-discrimination statutes.
Does Title VII of the Civil Rights Act of 1964 apply extraterritorially to prohibit employment discrimination against a U.S. citizen working for an American employer in a foreign country?
Under the presumption against extraterritoriality, federal statutes are presumed to apply only within the territorial jurisdiction of the United States unless Congress clearly expresses an affirmative intent for the statute to apply abroad. Absent such a clear statement, courts will not infer extraterritorial application from ambiguous text, general definitions, or legislative history.
No. Title VII, as it existed at the time of the case, did not apply extraterritorially to employment discrimination occurring in a foreign country, even where the plaintiff was a U.S. citizen employed by an American company.
Aramco is a cornerstone case for both employment law and statutory interpretation. First, it established that Title VII, as originally enacted, did not extend to U.S. citizens working for American employers abroad. Congress promptly responded by passing the Civil Rights Act of 1991, expressly extending Title VII's protections extraterritorially to U.S. citizens employed overseas by American employers and controlled foreign corporations, and creating a foreign law defense when compliance would violate the law of the host country. Second, Aramco powerfully reaffirmed the presumption against extraterritoriality, later relied on in decisions like Morrison and RJR Nabisco. For law students, the case illustrates how courts read statutory text narrowly with respect to geography absent a clear statement, the limited role of agency interpretations on questions of territorial scope, and the dynamic interplay between judicial interpretation and legislative amendment.