No Court Enforcement of Settlements

Wednesday, February 06, 2013

A recent decision by the U.S. Sixth Circuit Court of Appeals decided that employees do not have a right to seek enforcement of agreements settling their Title VII discrimination and retaliation claims in federal court. Taylor v. Geithner, No. 11-6122 (6th Cir. Jan. 2, 2013).

Taylor brought a Title VII claim of unlawful retaliation against her employer, the IRS. The parties eventually entered into a settlement agreement resolving Taylor’s complaint. However, she later claimed that the IRS had failed to comply with the terms of their settlement agreement and sought enforcement of the agreement in federal district court.

The IRS argued that the federal court could not hear Taylor’s case because it lacked jurisdiction over suits for enforcement of settlement agreements in Title VII claims. Specifically, the IRS argued that the doctrine of sovereign immunity, which bars suits against the government except where the government has specifically consented to be sued, applied to Taylor’s case and the district court could therefore not hear the case. The district court agreed that there was no statute granting the government’s consent to be sued in federal court for enforcement of a Title VII settlement agreement and dismissed the case for lack of jurisdiction.

Taylor appealed the decision to the U.S. Sixth Circuit Court of Appeals. She argued that applying the doctrine of sovereign immunity to her case would unfairly leave employees without the opportunity to seek federal review of compliance with settlement agreements in Title VII cases. The Sixth Circuit nevertheless affirmed the district court’s dismissal for lack of jurisdiction. It held that although federal courts may not meddle in issues of compliance with Title VII settlement agreements, employees may still seek enforcement of such agreements with the EEOC. The EEOC is in fact an employee-only forum for compliance issues related to settlement agreements.