Logan v. Zimmerman Brush Co.

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1982 U.S. Supreme Court case

1982 United States Supreme Court case

Logan v. Zimmerman Brush Co., 455 U.S. 422, is a unanimous 1982 decision of the U.S. Supreme Court concerning the Due Process Clause of the Fourteenth Amendment . The Court held that the petitioner was entitled to have his discrimination complaint adjudged by Illinois 's Fair Employment Practices Commission (FEPC), which had dismissed it for its own failure to meet a deadline. The decision reversed the Illinois Supreme Court 's holding to the contrary two years prior.

Logan, one of whose legs was shorter than the other , had been hired by Zimmerman in 1979 as a machine operator; when that proved beyond his capabilities, he was made a shipping clerk. A month later the company fired him for poor performance; within a week Logan brought a claim with FEPC, alleging he had been discriminated against due to his disability . FEPC was required to hold a factfinding conference with both parties within four months; it accidentally scheduled the one in Logan's case a week after that period ended. The company moved to dismiss the claim on those grounds; after FEPC's denial it petitioned the state Supreme Court for a writ of prohibition which was granted on the grounds that the statutory time limit was mandatory.

The U.S. Supreme Court granted Logan _certiorari _ to argue on appeal that his constitutional rights to equal protection and due process of law had been violated. Justice Harry Blackmun , writing for the Court, followed some of its other recent cases in holding that when the state created a process for Logan to seek redress, it had also created a property interest in any claims filed through that process which could not itself be deprived without due process. Unusually, Blackmun also wrote a separate concurrence to the majority opinion, joined by three other justices, arguing that the Illinois Supreme Court had also violated Logan's right to equal protection of the laws by arbitrarily creating two classes of complainants but only granting full rights to one purely on the basis of its own deadline. Justice Lewis Powell also concurred, but would have decided the case on narrower grounds specific to Logan's circumstances, rejecting Blackmun's "broad pronouncements".

The Court has not revisited Logan in any later case, but it has often been cited as establishing a test for when due process has been denied. Lower courts have sometimes had to choose between Logan and the _Parratt v. Taylor _ decision two years earlier (later overruled in part) as guiding precedent based on the record before them. Legal scholars have, in considering how it held Logan's claim a property interest, found it to straddle the line between procedural and substantive due process . It has also been described as the first time a majority of justices agreed that a challenged regulation failed the rational basis test under the Fourteenth Amendment. In the wake of the decision Illinois reformed the statute and replaced the FEPC with the Illinois Human Rights Commission, part of the newly created Illinois Department of Human Rights .

Background

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In 1961 the Illinois legislature passed the state's Fair Employment Practices Act (FEPA). It created the Fair Employment Practices Commission (FEPC), an administrative body empowered to hear and resolve complaints of employment discrimination in all categories protected by law. Early in its existence it incurred the wrath of large businesses; in 1964 Motorola offered to pay the legal bills of any small businesses in the state facing proceedings before the FEPC after it spent $200,000 fighting a decision to award $1,000 to an unsuccessful applicant. In 1975 the legislature added disability to the law's protected classes , but made FEPC the exclusive venue for resolving those complaints. : 25–26 

The FEPA set a deadline of 180 days from the alleged offense for complaints to be brought, and required only that FEPC notify any employer of a complaint against them within 120 days. After the state's Supreme Court held in its 1978 case Springfield-Sangamon County Regional Plan Commission v. Fair Employment Practices Commission that the deadlines were mandatory, not merely directory , the statute was amended to require that FEPC convene a fact-finding conference with the parties within the 120-day deadline, to promote speedier resolution of complaints and encourage negotiated settlements. In 1979, in a suit against FEPC brought by Chicago State University and another employer after the commission had waited two years to inform the latter of a pending complaint against it, the state Supreme Court not only reaffirmed its earlier ruling but clarified that if FEPC failed to notify the employer within 180 days of receiving the complaint, it lost jurisdiction permanently.

Underlying dispute

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In early October 1979 Laverne L. Logan was hired by the Zimmerman Brush Co., a Chicago manufacturer.

According to the company's lawyer, at that time it was fully aware that Logan's left leg was several inches shorter than his right . Zimmerman tried to accommodate him by assigning him first to the shipping room, and then to work on a machine where he could sit. : 25–26 

After a month, while he was still in his probationary period and thus not yet covered by the union contract, : 25–26  the company let Logan go since he was unable to perform his duties satisfactorily. Five days later, on November 14, Logan, on his own, filed a complaint with Illinois 's Fair Employment Practices Commission (FEPC), alleging that he had been fired because of his physical disability in violation of state law.

In late January 1980 FEPC mailed to both Logan and Zimmerman notice that it had scheduled that conference for March 18. The company was also asked to complete and return a two-page questionnaire about its personnel practices and the circumstances of Logan's termination by March 10, which it did. At the conference, Zimmerman moved to dismiss Logan's complaint on the grounds that, since FEPC had mistakenly scheduled the conference for five days after the 120-day deadline had expired, it was no longer valid. FEPC denied the motion, so the company petitioned the Supreme Court of Illinois for a writ of prohibition barring FEPC from taking any further action; it granted a stay pending resolution of the case. Logan retained counsel and, since the six-month period for him to file a complaint had not yet lapsed, refiled.

In response, the legislature again amended FEPA to allow for the conference to take place after the 120-day deadline if both parties agreed. It took effect in July of that year.

Supreme Court of Illinois

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The court unanimously held for Zimmerman

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