Fort Bend Cnty. v. Davis, 139 S. Ct. 1843

Lois M. Davis, a Fort Bend County IT employee, alleged sexual harassment by a colleague and subsequent retaliation by her supervisor after she reported it; she was later fired for missing work to attend church.
Davis submitted an EEOC intake questionnaire (checked "religion" and "reasonable accommodation") and filed a formal EEOC charge months later; she received a right-to-sue notice and sued under Title VII alleging religion discrimination and retaliation.
District Court granted summary judgment for Fort Bend; Fifth Circuit affirmed as to retaliation and reversed on the religion claim; the Supreme Court denied certiorari on that appeal, and the case returned to district court on the religion claim.
Years into litigation, Fort Bend first raised the defense that Davis had not exhausted administrative remedies because her formal EEOC charge did not explicitly allege religion discrimination and argued this defect deprived the court of jurisdiction.
The District Court dismissed the religion claim as jurisdictionally barred; the Fifth Circuit reversed, holding the EEOC charge-filing requirement is nonjurisdictional and forfeited when not timely raised.
Supreme Court granted review to resolve a circuit split on whether Title VII's charge-filing precondition is jurisdictional or a nonjurisdictional claim-processing rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Title VII's EEOC charge-filing precondition is jurisdictional or a claim-processing rule	Davis: The charge requirement is a procedural precondition that can be forfeited if not timely raised	Fort Bend: The requirement is jurisdictional and may be raised at any time because it conditions the court's authority to hear Title VII claims	The Court held the charge-filing requirement is nonjurisdictional — a mandatory claim-processing rule that is forfeitable if not timely asserted
Whether failure to specify "religion" in the formal EEOC charge deprived the court of subject-matter jurisdiction	Davis: Her intake form and complaint reasonably alerted the agency and employer; failure to raise the charge issue earlier forfeits it	Fort Bend: Absent express religion allegations in the charge, the court lacks jurisdiction over the religion claim	Court treated this as an untimely procedural objection; because Fort Bend raised it late, it was forfeited (per Fifth Circuit affirmation)

Kontrick v. Ryan, 540 U.S. 443 (distinguishing jurisdictional rules from claim-processing rules)
Sebelius v. Auburn Regional Medical Center, 568 U.S. 145 (warning against overuse of "jurisdictional" label)
Arbaugh v. Y & H Corp., 546 U.S. 500 (statutory limitations are nonjurisdictional unless Congress clearly says so)
Reed Elsevier, Inc. v. Muchnick, 559 U.S. 154 (registration requirement treated as nonjurisdictional claim-processing rule)
Zipes v. Trans World Airlines, Inc., 455 U.S. 385 (Title VII filing time limits are nonjurisdictional)
Eberhart v. United States, 546 U.S. 12 (procedural rules may be mandatory but forfeitable)
Gonzalez v. Thaler, 565 U.S. 134 (distinguishing jurisdictional defects from waivable defenses)
Union Pacific R. Co. v. Locomotive Engineers, 558 U.S. 67 (discussing when statutory requirement may be jurisdictional)
Alexander v. Gardner-Denver Co., 415 U.S. 36 (describing EEOC's investigatory/conciliation role under Title VII)