A recent decision by the U.S. District Court for the Eastern District of Louisiana highlights a critical lesson for employers facing workplace discrimination claims: All employee filings with the Equal Employment Opportunity Commission (EEOC) should be heavily scrutinized—if an employee didn’t raise an issue in the EEOC charge, they may not be able to include it in a subsequent lawsuit.
Worker Claims Unlawful Discrimination
John Fernandez, an African-American employee at American Sugar Refining, Inc. (known for Domino Sugar), alleged in his lawsuit that he found himself at the center of a racially and sexually hostile work environment. According to court documents, he claimed his coworkers made racially offensive remarks, engaged in unwanted touching, and spread rumors about his mental health as a pretext (excuse) for his eventual termination.
The workplace incidents Fernandez described in his lawsuit painted a troubling picture. He alleged that fellow employees asked his opinion about a video with a racial slur in the title, that he was given what he called “a made-up job” to separate him from white coworkers, and that colleagues generally refused to work with him because of his race. He claimed that when he complained about false stories regarding his mental health, the company required him to undergo a mental evaluation.
After losing his job, Fernandez followed the required legal process by filing a complaint, or “charge,” with the EEOC. In his charge, he alleged “Disability, Race, [and] Retaliation” as the bases for his discrimination claim. Once he received a right-to-sue letter from the EEOC, Fernandez filed his lawsuit, alleging claims for race discrimination, sex discrimination, hostile work environment, and harassment under Title VII of the Civil Rights Act of 1964.
Realizing that Fernandez had not mentioned anything about sex discrimination in his EEOC charge, American Sugar Refining fought back, asking the court to dismiss the claim because he hadn’t properly exhausted his administrative remedies with the EEOC before bringing this aspect of his case in court.
Court Dismisses Unexhausted Claims
The court faced a critical question: Which of Fernandez’s claims were properly “exhausted” through his EEOC charge proceeding, and which went beyond what he originally alleged to the agency? The court explained that employment discrimination lawsuits require a specific process to be followed. Before employees can sue their employers in federal court, they first must file a timely charge with the EEOC and receive a statutory notice of their right to sue. However, the scope of what they later can argue in court is limited by what they originally complained about to the EEOC.
This doesn’t mean employees need to use perfect legal language in their EEOC charges. As the court noted, courts must interpret EEOC charges “in their broadest reasonable sense” and ask whether claims brought in later-filed lawsuits “can reasonably be expected to grow out of the charge of discrimination.” The key is whether there is a reasonable connection between the original EEOC charge and the claims being made in court.
Applying this standard, the court found that because Fernandez’s EEOC charge made no mention of sex-based discrimination, he could not bring this claim in court. The court noted that the EEOC charge focused on disability, race, and retaliation, and any sex discrimination claims could not “reasonably be expected to grow out of” the charge. The sex discrimination claim asserted in the lawsuit, therefore, was dismissed for failure to exhaust administrative remedies. Fernandez v. Am. Sugar Refin., Inc., No. 25-772, 2025 LX 339024 (E.D. La., Aug. 8, 2025).
Takeaway
The decision serves as a practical reminder that while the EEOC complaint process doesn’t require legal perfection, charges filed with the EEOC at least must provide some detail about all claims that could arise in a lawsuit down the line. If an employee misses a key category of discrimination in the initial EEOC filing, it can result in losing the right to pursue that claim in court, even if the underlying facts support it.
Connor H. Fields is an associate in the labor and employment practice group of Jones Walker, LLP, in the firm’s New Orleans office. He can be reached at cfields@joneswalker.com or 504-582-8606.