Prairie View A&M University v. Diljit K. Chatha
381 S.W.3d 500
| Tex. | 2012Background
- Ther Texas Commission on Human Rights Act (TCHRA) provides 180-day filing window for discrimination claims under §21.202.
- Chatha, a Prairie View A&M professor, alleged pay discrimination based on race/national origin in 2005; Promoted to full professor in 2004.
- Chatha filed EEOC/TWC complaints; suit filed in state court for pay discrimination under the TCHRA.
- University argued complaint was untimely under §21.202; Chatha argued Ledbetter Act applies to TCHRA claims.
- Court held Ledbetter Act does not apply to the TCHRA; thus timeline is governed by 180 days from notice of pay decision.
- Court treated §311.034 as making administrative filing prerequisites jurisdictional when the defendant is a government entity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the Ledbetter Act apply to TCHRA pay claims? | Chatha | University | Ledbetter Act does not apply to TCHRA pay claims |
| Are federal amendments to Title VII automatically incorporated into the TCHRA? | Chatha | University | No automatic incorporation; Legislature must amend TCHRA |
| Is the 180-day filing deadline a statutory prerequisite to suit under §311.034 for governmental entities? | Chatha | University | Yes, 180-day deadline is a statutory prerequisite to suit for government entities |
| Did Chatha's complaint fall within the 180-day period under the TCHRA? | Chatha | University | Complaint untimely under 180-day rule; jurisdictional bar |
Key Cases Cited
- Specialty Retailers v. DeMoranville, 933 S.W.2d 490 (Tex. 1996) (180-day period begins when informed of discriminatory decision)
- Lorance v. AT&T Techs., Inc., 490 U.S. 900 (U.S. 1989) (discriminatory act occurs at adoption, not its effects)
- Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (U.S. 2007) (Ledbetter Act expands pay-discrimination timing to each paycheck)
- Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71 (Tex. 2000) (jurisdictional overruled for statutory prerequisites; time limits treated as non-jurisdictional)
- In re United Services Automobile Ass’n, 307 S.W.3d 299 (Tex. 2010) (sovereign immunity and prerequisites context in statutory waivers)
- Zipes v. Trans World Airlines, Inc., 455 U.S. 385 (U.S. 1982) (filing deadlines are claim-processing rules, not jurisdictional prerequisites)
- City of DeSoto v. White, 288 S.W.3d 389 (Tex. 2009) (statutory language governs whether a requirement is jurisdictional)
- In re United Services Automobile Ass’n, 307 S.W.3d 299 (Tex. 2010) (affirmative defense vs. jurisdictional status for limitations under TCHRA context)