Arbaugh v. Y & H Corp., 546 U.S. 500 (2006), is a United States Supreme Court decision involving Title VII of the Civil Rights Act of 1964, which provides a private cause of action to victims of employment discrimination.
Her complaint alleged sexual harassment in violation of Title VII, in addition to various tort claims under Louisiana state law.
Arbaugh's complaint asserted that her Title VII claim invoked the court's federal question jurisdiction to hear her case.
[3] If Arbaugh did not state a valid claim under Title VII, Y&H argued that she accordingly failed to invoke federal question jurisdiction.
[6] The court ruled that dismissal for want of subject matter jurisdiction was proper because the record warranted the conclusion that Y&H did not employ the requisite 15 employees.
Solicitor General was granted permission to participate in oral argument as amicus curiae, to argue in support of Arbaugh's legal interpretation.
[8] The Supreme Court unanimously[9] reversed the Fifth Circuit's decision in an opinion delivered by Justice Ruth Bader Ginsburg, holding that the threshold number of employees for application of Title VII is an element of a plaintiff's claim for relief, not a jurisdictional issue.