This Note analyzes the Supreme Court's decision in West v. Gibson against the backdrop of the new damages provisions of the Civil Rights Act of 1991 and the EEOC system for federal employees. Section II provides a brief legislative history of the 1991 CRA, outlines the EEOC complaint procedure specifically tailored to federal sector employees, and describes the cases leading up to West v. Gibson. Section III describes the Supreme Court's reasoning in Gibson, and Section IV analyzes the decision, concluding that, given the realities of congressional compromise and systemic constraints, the Supreme Court's decision actually does little to benefit federal employment discriminatees in the administrative process, at least in terms of allowing them to recover compensatory damages.
Royer, Christina M.
"West v. Gibson: Federal Employees Win the Battle, But Ultimately Lose the War for Compensatory Damages Under Title VII,"
Akron Law Review: Vol. 33
, Article 4.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol33/iss3/4