In Butts v. The City of New York Dept. of Housing, Preservation and Development, [FOOTNOTE 1] the Second Circuit stated that, “a district court only has jurisdiction to hear Title VII claims that either are included in an EEOC [Equal Employment Opportunity Commission] charge or are based on conduct subsequent to the EEOC charge which is ‘reasonably related’ to that alleged in the EEOC charge.” [FOOTNOTE 2]
The Second Circuit went on to “recogniz[e] three situations where claims not alleged in an EEOC charge are sufficiently related to the allegations in the charge that it would be unfair to civil rights plaintiffs to bar such claims in a civil action.” [FOOTNOTE 3] The Second Circuit described the three situations as follows:
