Whether a federal court may reject the doctrine of continuing violations in a Title VII hostile-work-environment case and eliminate from consideration all Complaint allegations that occurred more than 300 days prior to the date plaintiff filed an EEOC charge

QUESTIONS PRESENTED Petitioner Deana Pollard Sacks was a tenured professor at the Thurgood Marshall School of Law (TMSL) at Texas Southern University (TSU) until 2020. She filed two lawsuits against TSU, Sacks-I in 2018 and Sacks-II in 2022. Sacks alleged violations of Title VII for sex discrimination, a hostile environment, and retaliation, inter alia. The Title VII claims were dismissed in both cases for failure to state a claim and the United States Court of Appeals for the Fifth Circuit affirmed. This petition concerns Sacks-I. The petition for certiorari for Sacks-I was filed February 14, 2024. The District Court rejected continuing violations and granted summary judgment for all defendants as to all claims other than the non-retaliation EPA claim against TSU. The court did not allow Petitioner to discover female wage data or to amend her complaint to add EPA comparators once she discovered which male professors were paid higher wages, among many other issues that Petitioner appealed. The following issues are presented: 1. Whether a federal court may reject the doctrine of continuing violations in a Title VII case and eliminate from consideration all Complaint allegations that occurred more than 300 days prior to the date plaintiff filed an EEOC charge. 2. Whether a federal court may deprive an EPA plaintiff of female wage data and require her to identify male comparators before she knows which males were paid higher wages. ii 3. Whether this Court overruled Swierkiewicz and changed the pleading standard for Title VII cases by its decisions in Twombly and Iqbal, and if so, whether Iqbal empowers trial courts to disregard factual allegations, make factual findings to determine “plausibility,” and/or adopt pleading burdens in direct conflict with this Court’s pre-Igbal precedent. 4. Whether a federal court may reject this Court’s summary judgment standards and make findings of disputed fact in a summary judgment proceeding post-Iqgbal.