Stanley Chenault v. United States Postal Service

This appeal by Stanley Chenault from the district court’s denial of his motion to amend his complaint and dismissal of his action after a two-day bench trial by a magistrate judge requires us to determine whether certain sections of the Civil Rights Act of 1991 may be applied retroactively. Specifically, we must examine Section 102, which provides for compensatory and punitive damages as well as a jury trial in employment discrimination cases, Section 107, which creates a new framework for analyzing mixed-motive discrimination claims, and Section 114(1), which extends the period for filing discrimination claims against the federal government from 30 days to 90 days, in light of Landgraf v. USI Film Prods., — U.S. —, 114 S.Ct. 1483 , 128 L.Ed.2d 229 (1994) and Rivers v. Roadway Express, Inc., — U.S. —, 114 S.Ct. 1510 , 128 L.Ed.2d 274 (1994). We conclude that none of the sections in question may be applied retroactively and therefore affirm the judgment of the district court.

The district court had jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1343, and 29 U.S.C. § 794a(a)(l). We have jurisdiction under 28 U.S.C. § 1291 . Appeal was timely filed under Rule 4(a) of the Federal…