Arbaugh v. Y&H Corp

In Arbaugh v. Y&H Corp., 546 U.S. 500 (2006), the Supreme Court held that the threshold number of employees for application of Title VII is an element of a plaintiffs claim for relief, not a jurisdictional issue. Id. at 516. The Supreme Court noted that nothing in the text of Title VII indicates that Congress intended courts, on their own motion, to assure that the employeenumerosity requirement is met. Id. at 514. In Arbaugh Y & H Corp., 546 U.S. 500, 126 S.Ct. 1235, 163 L.Ed.2d 1097 (2006), the Supreme Court considered the provision of Title VII limiting its applicability to businesses over a certain size. Id. at 504-05, 126 S.Ct. 1235 (citing 42 U.S.C. 2000e(b) (defining "employer" to include only those entities having "fifteen or more employees")). The district court had determined, after trial, and on the employer's motion, that it lacked subject matter jurisdiction because the defendant employed fewer than fifteen employees, and consequently dismissed the case. The Fifth Circuit affirmed. The Supreme Court reversed, noting that the statutory provision at issue did not speak in jurisdictional terms, and concluding that the factual issue of whether the defendant had fifteen or more employees was not a jurisdictional limitation but an element of the claim for relief. Id. at 513-16, 126 S.Ct. 1235. The Court explained, "When Congress does not rank a statutory limitation on coverage as jurisdictional, courts should treat the restriction as nonjurisdictional in character." Id. at 516, 126 S.Ct. 1235. Cf. Partington v. Am. Int'l Specialty Lines Ins. Co., 443 F.3d 334, 338-39 (4th Cir. 2006) (applying Arbaugh and finding that the district court properly exercised jurisdiction in a case involving alleged violations of the Securities Act of 1933). The Court created a bright-line rule for analyzing whether a statutory provision implicates our subject matter jurisdiction: If the Legislature clearly states that a threshold limitation on a statute's scope shall count as jurisdictional, then courts and litigants will be duly instructed and will not be left to wrestle with the issue . . . But when Congress does not rank a statutory limitation on coverage as jurisdictional, courts should treat the restriction as nonjurisdictional in character. (Arbaugh, 546 U.S. at 515-16, 126 S.Ct. 1235.) The Court then applied its "readily administrable bright line" to find that the numerosity requirements in Title VII were not jurisdictional but "an element of a plaintiff's claim for relief." (Id. at 516, 126 S.Ct. 1235.) In Arbaugh v. Y & H Corporation, 546 U.S. 500 (2006), the Supreme Court set forth a readily administrable bright line jurisdictional standard. Id. at 516. If the Legislature clearly states that a threshold limitation on a statutes scope shall count as jurisdictional, then courts and litigants will be duly instructed and will not be left to wrestle with the issue. Id. at 515-16. In Arbaugh v. Y & H Corp., 546 U.S. 500 , 514 (2006), the Supreme Court explained its approach to distinguishing jurisdictional prescriptions from other requirements, such as claims-processing rules: If the Legislature clearly states that a threshold limitation on a statutes scope shall count as jurisdictional, then courts and litigants will be duly instructed and will not be left to wrestle with the issue. But when Congress does not rank a statutory limitation on coverage as jurisdictional, courts should treat the restriction as nonjurisdictional in character. Arbaugh, 546 U.S. at 515-16. The plaintiff in Arbaugh brought a claim under Title VII of the Civil Rights Act of 1964, which makes it unlawful for an employer . . . to discriminate, inter alia, on the basis of sex. Reed Elsevier. 130 S. Ct. at 1244 (quoting 42 U.S.C. 2000e-2(a)(1)). But employees can bring Title VII claims only against employers that have fifteen or more employees. Id. (quoting 42 U.S.C. 2000e(b)). The question in Arbaugh was whether that employee numerosity requirement affects federal-court subject-matter jurisdiction or, instead, delineates a substantive ingredient of a Title VII claim for relief. Id.