District Court Joins A Harmony Of Rulings That Apply § 706's Limitations Period To EEOC Pattern Or Practice Allegations Brought Under § 707 Of Title VII

In EEOC v. Global Horizons Inc., No. 11-CV-00257 (D. Haw. Nov. 8, 2012), the EEOC attempted to force a square peg into a round hole by transforming headline grabbing allegations of human trafficking into a Title VII pattern or practice case; even more problematic is that the EEOC attempted to argue that there is no applicable statute of limitations that applies to the §707 pattern or practice claims it asserted in the case. However, Judge Alan Ezra of the U.S. District Court for the District of Hawaii recently dismissed a significant portion of the EEOC’s allegations, holding that the EEOC’s claims for alleged unlawful employment actions under § 707 must adhere to the 300-day limitations period set forth by § 706 of Title VII. Applying this critical limitation on the EEOC’s pattern or practice claims, Judge Ezra dismissed all of the EEOC’s claims seeking relief for employment practices occurring more than 300-days before the filing of the underlying administrative charge.

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