Jeanette J. PLUMMER, Plaintiff-Appellant, v. WESTERN INTERNATIONAL HOTELS COMPANY, INC., Defendant-Appellee

Jeanette Plummer, a black person, filed a civil rights suit against her employer, Western International Hotels Company (Western), alleging racial discrimination in passing her over for promotion despite her qualifications and seniority. The district court entered judgment on a jury verdict for Western. Plummer contends that the district court committed reversible error by excluding from evidence a finding of “reasonable cause” by the Equal Employment Opportunity Commission (EEOC), and by applying Oregon’s two year statute of limitations to limit her claim under 42 U.S.C. § 1981 . We agree with both contentions, reverse the district court judgment for Western, and remand for a new trial. FACTS

Plummer began working as a hostess for Western in 1960, and was promoted to general cashier in 1965, a position she held until her disability retirement in 1978. The parties agree that Plummer performed her job well, and witnesses for Western testified that Plummer was offered several opportunities for promotion, which she turned down.

In March of 1973, Wanda Goodrich, a white woman, was promoted to assistant controller, although she had less seniority than Plummer. At trial, Plummer…