Carolyn Sydnor v. Fairfax County, Virginia
681 F.3d 591
4th Cir.2012Background
- Sydnor, a Fairfax County public health nurse, underwent left-foot surgery in January 2009 and was terminated in November 2009 due to post-surgery restrictions.
- She filed an EEOC charge on December 18, 2009 alleging disability discrimination and denial of a reasonable accommodation; the EEOC intake described her disability and requested light-duty work.
- The EEOC issued a right-to-sue notice on August 10, 2010, and Sydnor filed suit in federal court within ten days.
- The district court dismissed sua sponte for failure to exhaust administrative remedies, distinguishing between light-duty and a wheelchair-based accommodation not listed in the EEOC intake.
- Sydnor argued exhaustion was satisfied because the proposed wheelchair accommodation followed logically from her documented disability and the EEOC questionnaire, and was reasonably related to the charge.
- The Fourth Circuit reversed and remanded, holding that Sydnor exhausted administrative remedies and that the case should proceed consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Sydnor exhaust administrative remedies? | Sydnor's claims were reasonably related to the EEOC charge and questionnaire. | Wheelchair accommodation was not listed in the EEOC materials, so exhaustion failed. | Exhaustion satisfied; proceed. |
| Are the administrative and judicial claims reasonably related in scope? | Charges and suit concern same employer, same actor, and related discriminatory conduct. | Different proposed accommodations created a gap between administrative and judicial claims. | Yes, reasonably related; no failure of exhaustion. |
| Can a wheelchair accommodation be reasonably investigated as part of the administrative process? | Disability description and supervisor statements put wheelchair as a logical accommodation; EEOC investigation would cover it. | Administrative documents did not specify the wheelchair accommodation, breaking exhaustion. | Wheelchair accommodation reasonably follows from the disability and is encompassed within a reasonable investigation. |
Key Cases Cited
- Chacko v. Patuxent Inst., 429 F.3d 505 (4th Cir. 2005) (exhaustion scope depends on reasonably related claims and notice)
- Miles v. Dell, Inc., 429 F.3d 480 (4th Cir. 2005) (EEOC notice and early resolution; not a strict formality)
- Smith v. First Union Nat’l Bank, 202 F.3d 234 (4th Cir. 2000) (claims may be exhausted if reasonably related to EEOC charge)
- Chisholm v. U.S. Postal Serv., 665 F.2d 482 (4th Cir. 1981) (administrative and judicial narratives must describe related conduct and actors)
- Fed. Express Corp. v. Holowecki, 552 U.S. 389 (Sup. Ct. 2008) (administrative filings should protect employee rights and remedies; not overly technical)
- Thornton v. United Parcel Serv., Inc., 587 F.3d 27 (1st Cir. 2009) (reasonable investigation can cover details beyond explicit enumerations)