In Riley v. Technical & Management Services Corp., 872 F. Supp. 1454 (D. Md. 1995), the United States District Court observed that "allowing a complaint to encompass allegations outside the ambit of the predicate EEOC charge circumvents the EEOC's investigatory and conciliatory role." Id. at 1459.
The plaintiffs raised two causes of actions in the federal district court that were not raised in the administrative action.
In their EEOC complaint, the plaintiffs alleged only discrimination based on their gender. Id. But later, in defending their judicial complaint against a defense motion for summary judgment, they claimed not only gender discrimination but sexual harassment, hostile work environment, and retaliation. Id. at 1459. Rejecting those newly-raised claims, the district court explained that it could "only exercise jurisdiction over claims encompassed within the EEOC charge and claims 'like or related to allegations contained in the charge, or which grow out of such allegations.'" Id. (quoting Nealon v. Stone, 958 F.2d 584, 590 (4th Cir. 1992)).