Williams v. Pa. Human Relations Comm’n, 2017 U.S. App. LEXIS 16618 (3d. Cir. Aug. 30, 2017)

Third Circuit holds that plaintiffs may not seek damages pursuant to Section 1983 for stand-alone violations of Title VII or the ADA.

The plaintiff, an investigator with the Pennsylvania Human Relations Commission, alleged that her supervisors subjected her to harassment on the basis of her race and constructively discharged her, in violation of Title VII and the Americans with Disabilities Act. The plaintiff further sought damages from her supervisors, individually, pursuant to Section 1983. Following the trial court’s order granting the Commission’s motion for summary judgment, the plaintiff appealed to the Third Circuit. In this case of first impression, the Third Circuit addressed “[w]hether violations of Title VII and the ADA may be brought through [Section] 1983.” In affirming the trial court’s decision, the Third Circuit expressly stated, “In light of the comprehensive administrative scheme established by Title VII and the ADA, we conclude that these claims, standing alone, may not be asserted under [Section] 1983.” In holding that the plaintiff could not seek damages under Section 1983, the Third Circuit noted that its decision was in line with every circuit that had addressed the issue. Notably, the court reasoned that Congress did not intend for Section 1983 to serve as a remedy for a violation of Title VII and the ADA when it created an entirely separate administrative process for those statutes. Indeed, the Third Circuit outlined all of the administrative steps a plaintiff is required to exhaust before pursuing Title VII and ADA claims in court. Whereas Section 1983 “[h]as only a one-step ‘remedial scheme,’ plaintiffs may file [Section 1983] suits directly in federal court.” In conclusion, the Third Circuit determined that, “[g]iven these respective statutes, Congress’s intent is clear” and “[a]llowing pure Title VII and ADA claims under [Section] 1983 would thwart Congress’s carefully crafted administrative scheme by throwing open a back door to the federal courthouse when the front door is purposely fortified.”


Case Law Alerts, 4th Quarter, October 2017

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