Sex Discrimination in a Retaliation Action. A plaintiff filed a complaint with the EEOC, claiming that her employer had discriminated against her. While she had only checked Retaliation on her Charge of Discrimination form, she had alleged acts of sexual discrimination. The EEOC gave her a right to sue letter. She brought an action, alleging, among other things, claims of sexual discrimination. The District Court dismissed that claim, asserting that the plaintiff had not exhausted her administrative remedies.

The Second Circuit vacated the dismissal of the sex discrimination, holding that the sexual discriminaton was "reasonably related" to the retaliaion claim to allow the discrimination to be brought in federal court. The allegations were sufficeint to have put the EEOC on notice of a potential sex discrimination claim existed even though she did not check the SEX box on the Charge of Discrimination Form.

The decision in Williams v. New York City Housing Authority can be found at the Seconjd Circuit website. The case was decided on July 19, 2006.