Arbaugh v. Y & H Corp. Case Brief

Facts of the Case

“Plaintiff Jenifer Arbaugh brought a Title VII action in federal district court against her former employer, defendant Y & H Corporation, for sexual harassment. The case was tried to a jury, which returned a verdict for Arbaugh in the total amount of $ 40,000. Two weeks after the trial court entered judgment on the jury verdict, the employer moved to dismiss the entire action for want of federal subject-matter jurisdiction. For the first time in the litigation, Y & H asserted that it had fewer than 15 employees on its payroll and did not qualify as an employer subject to the prohibitions of Title VII. The employer further contended that the employee threshold was jurisdictional. On the otherhand, Arbaugh argued that the employee limitation was merely an element of her claim and that the employer waived its challenge to the requirement by not raising the issue until after trial. Although recognizing that it was “unfair and a waste of judicial resources” to grant the motion to dismiss, the trial court considered itself obliged to do so because it believed that the 15-or-more-employees requirement was jurisdictional.”

Question

Did Congress violate the Constitution in adopting the Child Labor Tax Law in attempting to regulate the employment of children, a power reserved to the states under the Tenth Amendment?

CONCLUSION

“The Court held that the number-of-employees requirement is an element of the merits of a Title VII claim, not a jurisdictional limitation. The 8-0 opinion (Justice Alito not participating) by Justice Ruth Bader Ginsburg reversed the Circuit Court, noting the “unfair[ness]” and “waste of judicial resources” that could result from a jurisdictional interpretation of the number-of-employees requirement as well as the lack of any specific jurisdictional language that would require such an interpretation. The Court relied on a “readily administrable bright line” rule that statutory limitations should be treated as non-jurisdictional unless specified as jurisdictional by Congress.”

Case Information

Citation: 546 US 500 (2006)
Granted: May 16, 2005
Argued: Jan 11, 2006
Decided: Feb 22, 2006
Case Brief: 2006