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Andrew Findlay v. Geoquip, Inc.

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 24-1894 · judgment April 14, 2025


Certiorari denied · October 6, 2025
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. Does the doctrine of res judicata bar a Title VII retaliation claim based on post-employment conduct when the prior lawsuit addressed only pre-termination conduct, particularly when the subsequent claims were not ripe during the prior litigation?

  2. Is a plaintiff required to amend an initial EEOC charge to include distinct acts of post-employment retaliation, or may they file a separate EEOC charge without violating Title VIPs administrative exhaustion requirements?

  3. Does the 300-day limitations period for filing an EEOC charge for a retaliatory lawsuit commence with a threat of litigation or with the actual filing of the lawsuit?

Counsel of record

For petitioner
Todd Michael Gaynor
Gaynor Law Center, P.C.

For respondent
Anne Graham Bibeau
Woods Rogers Vandeventer Black PLC

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Oct 06 2025
    Petition DENIED.
  2. Aug 20 2025
    DISTRIBUTED for Conference of 9/29/2025.
  3. Aug 15 2025
    Waiver of right of respondent Geoquip, Inc. to respond filed.
  4. Jul 14 2025
    Petition for a writ of certiorari filed. (Response due August 15, 2025)