Rodgers
Rodgers v. American Airlines, Inc.
Opinion
Lead Opinion
MEMORANDUM *
Plaintiff Darlene Mullen Rodgers appeals the district court’s summary judgment in favor of the defendant, American Airlines, in an action alleging Title VII racial discrimination and retaliation. The district court dismissed Rodgers’ complaint for failure to file a timely Equal Employment Opportunity Commission (“EEOC”) charge before commencing her suit. We reverse and remand for further proceedings.
This case is controlled by Casavantes v. California State University, Sacramento, 732 F.2d 1441 (9th Cir.1984), in which we held that the filing of an intake questionnaire was sufficient to serve as the filing of a charge when it gives the EEOC sufficient information to identify the parties and to describe the practices complained of. See id. at 1442-43 . We pointed out that our ruling was “consistent with the recent trend in Title VII jurisprudence which recognizes the importance of nontechnical interpretations of the procedural requirements inherent in the processing of discrimination claims.” Id. at 1442 . We also noted that “a liberal construction is particularly appropriate in situations in which the complainant is acting pro se.” Id.