In Rowe v. Poplar Grove Operations, LLC, 2025 WL 1184061 (E.D.Ark. April 23, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race discrimination claim asserted under Title VI of the Civil Rights Act of 1964.
This decision illustrates the “administrative exhaustion” requirement of Title VII, and the importance of including all pertinent claims in one’s EEOC charge.
From the decision:
Plaintiff’s race discrimination claim under Title VII is dismissed because she failed to exhaust her administrative remedies with respect to that claim. Plaintiff may only bring a Title VII suit as to alleged unlawful unemployment practices that are either described in her EEOC charge or like or reasonably related to them. Richter v. Advance Auto Parts, Inc., 686 F.3d 847, 851 (8th Cir. 2012). Plaintiff’s EEOC charge alleges that she was discriminated against on the basis of age. Rowe make no reference to race discrimination. Plaintiff’s race discrimination claim is not “like or reasonably related” to her claim of age discrimination, accordingly, she has not exhausted her administrative remedies as to her race discrimination claim. Robinson v. Am. Red Cross, No. 4:11-CV-00768-SWW, 2012 WL 79605, at *2 (E.D. Ark. Jan. 11, 2012), aff’d, 753 F.3d 749 (8th Cir. 2014) citing, Sallis v. Univ. of Minn., 322 F.Supp.2d 999, 1004 n. 1 (D. Minn. 2004) (“Age and race are distinct protected categories and the exhaustion of remedies with regard to one does not create a right to sue for the other.”), aff’d, 408 F.3d 470 (8th Cir. 2005).
Accordingly, dismissal was warranted.