536 U.S. 101 (2002)
National Railroad Passenger Corporation v. Morgan is a landmark case decided by the United States Supreme Court in 2002.
Does the statute of limitations for filing a Title VII claim regarding a hostile work environment reset with each incident within a series of acts that create such an environment, even if some acts fall outside the statutory period?
For claims of a hostile work environment under Title VII, the statute of limitations does not bar an employee from suing on specific acts whose timely filing period has lapsed, as long as the acts are all part of the same hostile work environment and at least one act falls within the filing period.
The Supreme Court held that a charge alleging a hostile work environment claim is timely if any act contributing to the hostile work environment falls within the 300-day or 180-day filing period. Morgan was allowed to use the entire time frame of his employment as evidence of the hostile work environment, provided that an act within the period was part of the hostile environment.
This case is significant for law students as it illustrates a critical interpretation of the statute of limitations in the context of employment discrimination law. It clarifies how courts should handle claims involving ongoing discriminatory conduct, and emphasizes the necessity for comprehensive judicial consideration of employment practices. The Court’s interpretation impacts the strategies employed by plaintiffs in civil rights litigation, particularly those alleging ongoing harassment.