context: All three individuals timely filed their own administrative charges, and in this lawsuit are pressing claims brought in those charges. It follows that Dancy, Shumaker, and Russell may not rely on McQueen's charge or any of its claims, including the disparate impact claim, in an effort to satisfy the exhaustion requirement.
citation_a.signal: see also
citation_a.identifier: 163 F.Supp.2d 19, 25
citation_a.parenthetical: "The single-file rule allows an individual plaintiff, who has not filed an EEOC charge, to satisfy the administrative exhaustion requirements under Title VII by relying on a charge filed by another plaintiff."
citation_a.sentence: See Holowecki, 440 F.3d at 564-65 (“allowing an individual who has previously filed a charge to abandon that charge and piggyback onto the charge of another individual would too often frustrate the EEOC’s statutorily-mandated efforts to resolve an individual charge through informal conciliation”); Gitlitz v. Compagnie Nationale Air France, 129 F.3d 554, 558 (11th Cir.1997) (“such a plaintiff should be required to rely upon his or her own ... charge, and cannot reasonably rely upon [an]other claimant’s charge”); Anderson v. Unisys Corp., 47 F.3d 302, 309 (8th Cir.1995) (“once they file separate administrative charges, they cannot rely any further on the other claimant’s actions and must timely file suit after receiving their right-to-sue letters”); Flemming, 2004 WL 2314962, at *2 (single-filing rule “implies that a plaintiff who does receive a right-to-sue letter may not enjoy the benefit of piggy-backing”); see also Campbell v. Nat’l R.R. Passenger Corp., 163 F.Supp.2d 19, 25 (D.D.C.2001) (“The single-file rule allows an individual plaintiff, who has not filed an EEOC charge, to satisfy the administrative exhaustion requirements under Title VII by relying on a charge filed by another plaintiff.”).
citation_b.signal: see
citation_b.identifier: 2004 WL 2314962, at *2
citation_b.parenthetical: single-filing rule "implies that a plaintiff who does receive a right-to-sue letter may not enjoy the benefit of piggy-backing"
citation_b.sentence: See Holowecki, 440 F.3d at 564-65 (“allowing an individual who has previously filed a charge to abandon that charge and piggyback onto the charge of another individual would too often frustrate the EEOC’s statutorily-mandated efforts to resolve an individual charge through informal conciliation”); Gitlitz v. Compagnie Nationale Air France, 129 F.3d 554, 558 (11th Cir.1997) (“such a plaintiff should be required to rely upon his or her own ... charge, and cannot reasonably rely upon [an]other claimant’s charge”); Anderson v. Unisys Corp., 47 F.3d 302, 309 (8th Cir.1995) (“once they file separate administrative charges, they cannot rely any further on the other claimant’s actions and must timely file suit after receiving their right-to-sue letters”); Flemming, 2004 WL 2314962, at *2 (single-filing rule “implies that a plaintiff who does receive a right-to-sue letter may not enjoy the benefit of piggy-backing”); see also Campbell v. Nat’l R.R. Passenger Corp., 163 F.Supp.2d 19, 25 (D.D.C.2001) (“The single-file rule allows an individual plaintiff, who has not filed an EEOC charge, to satisfy the administrative exhaustion requirements under Title VII by relying on a charge filed by another plaintiff.”).