Humberto Trujillo v. Rockledge Furniture
926 F.3d 395
| 7th Cir. | 2019Background
- Humberto Trujillo managed Ashley Furniture HomeStore locations in the Chicago area from 2007–2016; the stores were owned and operated by Rockledge Furniture LLC, which did business in Illinois as “Ashley Furniture HomeStore – Rockledge.”
- Trujillo filed an EEOC charge alleging age discrimination and retaliation; the charge named the employer as “Ashley Furniture HomeStore” and gave the store’s Illinois address and phone number but did not use the formal Rockledge name.
- The EEOC’s automated processing forwarded the charge to a Texas company (Hill Country Holdings, LLC), which was not Trujillo’s employer; Hill Country replied it had not employed him.
- Trujillo’s lawyer informed the EEOC that Rockledge was the employer and supplied a paystub showing Rockledge’s full corporate name and address, but the EEOC still did not serve Rockledge and eventually closed the file and issued a right-to-sue letter.
- Trujillo sued under the ADEA and Illinois Human Rights Act; the district court dismissed for failure to exhaust administrative remedies because Rockledge was not named in the EEOC charge and purportedly had no notice.
- The Seventh Circuit reversed, holding (1) the informal naming plus address/phone sufficiently identified the employer (and the paystub removed doubt), and (2) the EEOC’s processing error does not bar the suit; remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a minor naming error in an EEOC charge (using trade name instead of formal LLC name) defeats exhaustion | Trujillo: the charge provided sufficient identification (trade name + address/phone); liberal construction required | Rockledge: omission of the formal corporate name prevented notice and exhaustion | Court: minor naming error did not defeat exhaustion given trade name + correct address/phone; courts liberally construe charges |
| Whether supplemental information provided after misrouting (paystub naming Rockledge) can cure any naming defect | Trujillo: the paystub removed any doubt about the employer’s identity and should be considered | Rockledge: EEOC never served Rockledge; late materials cannot substitute for naming | Court: the lawyer’s paystub to the EEOC cures lingering doubts and is properly considered |
| Whether the EEOC’s failure to route/serve the charge on the correct employer bars suit | Trujillo: EEOC mishandling should not strip access to courts; focus is on information given to EEOC, not EEOC’s errors | Rockledge: lack of conciliation opportunity prejudiced Rockledge, justifying dismissal | Court: EEOC error does not bar suit; remedy is to allow conciliation if practicable, not dismissal |
| Whether the Eggleston actual-notice test governs here (unnamed defendant received notice) | Trujillo: this is not a complete failure to name; cases tolerating informal naming are more apt | Rockledge: Eggleston requires dismissal absent actual notice and opportunity to conciliate | Court: Eggleston line was inapt; apply cases allowing informal naming and liberal construction instead |
Key Cases Cited
- Federal Express Corp. v. Holowecki, 552 U.S. 389 (2008) (charge definition should be liberally construed and EEOC mishandling does not necessarily bar suit)
- Eggleston v. Chicago Journeymen Plumbers' Local Union No. 130, 657 F.2d 890 (7th Cir.) (1981) (allowing suit against unnamed party who received actual notice and chance to conciliate)
- Ezell v. Potter, 400 F.3d 1041 (7th Cir. 2005) (EEOC charge and complaint must describe same conduct and individuals for exhaustion)
- Husch v. Szabo Food Service Co., 851 F.2d 999 (7th Cir. 1988) (ADEA exhaustion requirements and liberal construction of charges)
- Steffen v. Meridian Life Ins. Co., 859 F.2d 534 (7th Cir. 1988) (focus on information provided to EEOC, not EEOC’s later actions)
- Mach Mining, LLC v. EEOC, 135 S. Ct. 1645 (2015) (if EEOC fails to attempt conciliation, remedy is to order conciliation, not dismissal)