Schroeder v. Texas Iron Works, Inc.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Schroeder's requirement to pursue administrative remedies before suing was not overruled by that decision. Later courts disagreed or expressed doubt about whether the separate 180-day deadline to file an administrative charge is jurisdictional. Source note: The actual overruling opinion, In re United Services Automobile Ass'n, was read and saved with the citing opinions. Many other opinions mention its ruling only in citation histories. One assigned 2025 document is an appellee's brief rather than a judicial opinion and supplies no treatment.
54 later cases cite Schroeder v. Texas Iron Works, Inc.; 54 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 Schroeder v. Texas Iron Works, Inc.?
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
Overruled in part
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The Supreme Court of Texas overruled Schroeder's statement that the Act's two-year deadline for filing suit is jurisdictional, while leaving its administrative-exhaustion holding in place.
In re United Services Automobile Ass'n · Supreme Court of Texas · filed
But we have never revisited our statement in Schroeder, even though courts have questioned whether Schroeder remains the law after Dubai. ... we conclude that the two-year period for filing suit is mandatory but not jurisdictional, and we overrule Sehroeder to the extent it held otherwise.
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Declined to follow
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The Fifth Circuit rejected Schroeder's jurisdictional characterization of the Act's 180-day deadline to file an administrative charge, while holding the deadline mandatory.
Hinkley v. Envoy Air, Incorporated · Fifth Circuit · filed
The Texas Supreme Court had previously concluded this deadline is “mandatory and jurisdictional”. Specialty Retailers, Inc. v. DeMoranville, 933 S.W.2d 490, 492 (Tex. 1996) (per curiam) (citing Schroeder, 813 S.W.2d at 485–86). ... Applying In re USAA and Gorman, we conclude § 21.202’s 180-day filing deadline, although mandatory, is not jurisdictional. ... Accordingly, we hold that Texas Labor Code § 21.202’s 180-day filing requirement is mandatory but not jurisdictional.
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Limited
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The Texarkana Court of Appeals declined to extend Schroeder's jurisdictional rule for a missing administrative complaint to a complaint that was filed but not verified.
Reid v. SSB Holdings, Inc. · Court of Appeals of Texas, Sixth District, Texarkana · filed
By contrast, the plaintiff in Schroeder completely failed to file a complaint with the Commission, and the administrative system of review provided under the TCHRA was not invoked before he filed his civil suit. See Schroeder, 813 S.W.2d at 485–86. Thus, the Texas Supreme Court was not presented with the question of whether a plaintiff who files a complaint with the Commission, but fails to verify it, as here, is jurisdictionally barred from bringing a civil suit. ... we find that Reid’s failure to verify her complaint filed with the Commission did not deprive the trial court of subject-matter jurisdiction.
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Questioned
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The Houston Court of Appeals questioned whether Schroeder's jurisdictional rule for an untimely administrative charge applies to suits between private parties, without deciding that issue.
Yeh v. Chesloff · Court of Appeals for the First District of Texas · filed
We frame the issue regarding a failure to comply with Chapter 21’s administrative exhaustion requirement as a defense to liability, rather than a jurisdictional bar, mindful that the Texas Supreme Court’s decision in Prairie View A&M University v. Chatha raises questions about whether the failure to satisfy Chapter 21’s administrative exhaustion requirement implicates trial court jurisdiction in a suit between private parties. See 381 S.W.3d 500, 510–11 (Tex. 2012); compare Schroeder, 813 S.W.2d at 488 (holding that failure to comply with the 180-day deadline for filing a charge is a jurisdictional bar, even in suits between private parties, because Texas Commission on Human Rights Act does not provide an unconditional private right of action)
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A federal district court questioned whether Schroeder's jurisdictional exhaustion rule remains valid for suits between private parties.
Hancock v. Securitas Security Services USA, Inc. · Western District of Texas · filed
The Texas Supreme Court has previously held that the Texas Labor Code’s exhaustion requirement is “mandatory and jurisdictional.” See Specialty Retailers, Inc. v. DeMoranville, 933 S.W.2d 490, 492 (Tex. 1996); Schroeder v. Tex. Iron Works, Inc., 813 S.W.2d 483, 486 (Tex. 1991). But its more recent decisions have called this holding into question with respect to cases involving private litigants.
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