Banerjee v. Board of Trustees of Smith College

How later courts describe this case

• treating § 1981 and Title VII as coextensive, the primary difference only in the scope of relief available under each statute
• formulating the “relatively near to the time” fourth prong in a tenure denial case
• requiring employer to articulate reason serves in part the purpose of “framing] the factual issue with sufficient clarity so that the plaintiff will have a full and fair opportunity to demonstrate pretext”
• federal district court may order state court judge to confer with United States attorney because "ban on federal directives to state courts is not absolute...."
• discriminatory employment complaint untimely; plaintiff failed to allege "additional overt discriminatory acts” in the limitations period
• federal district court may order state court judge to confer with United States attorney because “ban on federal directives to state courts is not abso-lute_"
• attempt by union to discharge Seventh Day Adventists for refusal to join or pay dues
• federal courts in section 1983 actions borrow applicable state statute of limitations