Jones v. Calvert Group, Ltd.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The 3 confirmed treatments listed below concern its characterization of charge filing as jurisdictional; courts continue to apply its rules on the scope of an EEOC charge and related post-charge retaliation. Fort Bend County v. Davis displaced Jones's Title VII jurisdictional rule. A district court separately applied Fort Bend's reasoning to Jones's ADEA jurisdictional rule.
307 later cases cite Jones v. Calvert Group, Ltd.; 74 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Jones v. Calvert Group, Ltd.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Abrogated
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The Supreme Court rejected Jones's rule that failure to satisfy Title VII's EEOC charge-filing requirement deprives federal courts of subject-matter jurisdiction.
Fort Bend County v. Davis · Supreme Court of the United States · filed
... We granted Fort Bend’s petition for certiorari, 586 U. S. ___ (2019), to resolve a conflict among the Courts of Ap-peals over whether Title VII’s charge-filing requirement is jurisdictional. Compare, e.g., 893 F. 3d, at 306 (case be-low) (charge-filing requirement is nonjurisdictional), with, e.g., Jones v. Calvert Group, Ltd., 551 F. 3d 297, 300 (CA4 2009) (federal courts lack subject-matter jurisdiction when the charge-filing requirement is not satisfied). We hold that Title VII’s charge-filing instruction is not jurisdictional
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Declined to follow
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The Fifth Circuit adopted a nonjurisdictional Title VII exhaustion rule and identified Jones's opposite rule as contrary authority.
Lois Davis v. Fort Bend County · Fifth Circuit · filed
but see Logsdon v. Turbines, Inc., 399 F. App’x 376, 379 n.2 (10th Cir. 2010) (noting that in the Tenth Circuit “EEOC exhaustion is still considered jurisdictional” even if undermined by recent Supreme Court cases (quoting In re Smith, 10 F.3d 723, 724 (10th Cir. 1993))); Jones v. Calvert Grp., Ltd., 551 F.3d 297, 300 (4th Cir. 2009) (“[A] failure by the plaintiff to exhaust administrative remedies concerning a Title VII claim deprives the federal courts of subject matter jurisdiction over the claim.”).
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The district court held that Jones's ADEA exhaustion rule was also nonjurisdictional under Fort Bend's reasoning and addressed exhaustion under Rule 12(b)(6).
Hodge v. Walrus Oyster Ale House · District of Maryland · filed
Although Jones also held that the analogous ADEA exhaustion requirement was jurisdictional, Jones, 551 F.3d at 301, the reasoning of Davis applies equally to that provision and therefore compels the conclusion that it, too, is non-jurisdictional.
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