Andrew Findlay v. Geoquip, Inc.
SocialSecurity ERISA TradeSecret EmploymentDiscrimina
Does the doctrine of res judicata bar a Title VII retaliation claim based on post-employment conduct when the prior lawsuit addressed only pre-termination conduct, and does the 300-day limitations period commence with a threat of litigation or actual lawsuit filing?
1. Does the doctrine of res judicata bar a Title VII retaliation claim based on post-employment conduct when the prior lawsuit addressed only pre-termination conduct, particularly when the subsequent claims were not ripe during the prior litigation? 2. Is a plaintiff required to amend an initial EEOC charge to include distinct acts of post-employment retaliation, or may they file a separate EEOC charge without violating Title VIPs administrative exhaustion requirements? 3. Does the 300-day limitations period for filing an EEOC charge for a retaliatory lawsuit commence with a threat of litigation or with the actual filing of the lawsuit? ii RELATED CASES 1. Findlay v. Geoquip, Inc., No. 2:24-cv-147, United States District Court for the Eastern District of Virginia, Judgment entered August 16, 2024. 2. Findlay v. Geoquip, Inc., No. 24-1894, United States Court of Appeals for the Fourth Circuit, Judgment entered April 14, 2025