Case Explained: Non-Argument Calendar SHANNON BAZEMORE v. INTERNATIONAL LONGSHOREMEN’S ASSOCIATION ILA LOCAL 1475

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-01 Docket: 4:23-cv-00372-RSB-CLR The Eleventh Circuit affirmed the district court’s dismissal of Shannon Bazemore’s employment discrimination complaint against the International Longshoremen’s Association, Local 1475. The court held that the plaintiff failed to exhaust her administrative remedies and failed to state a claim for relief under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991. Regarding the exhaustion of administrative remedies, the court applied the standard that a plaintiff must file an EEOC charge within 180 days of the alleged unlawful employment action in non-deferral states like Georgia. The court determined that the discrete acts Bazemore challenged—specifically the September 2021 waiver and the October 1, 2021 Memorandum of Understanding (MOU)—occurred more than 180 days before she filed her initial charge on September 1, 2022. The court rejected the argument that the continuing violation doctrine applied, finding that Bazemore failed to identify repeated or ongoing violations that would allow time-barred claims to proceed. Regarding the failure to state a claim, the court applied the plausibility standard established in *Bell Atlantic Corp. v. Twombly* and *Ashcroft v. Iqbal*. The court concluded that the facts alleged, accepted as true, did not suggest intentional racial discrimination because the seniority plan changes were race-neutral and applied to both white and African American members. Furthermore, the court found that the single text message from a union member cited by Bazemore was insufficient to support a hostile work environment claim, as it did not mention race, was not pervasive, and failed to allege facts showing it altered the terms and conditions of her employment. The practical consequence is that the district court’s dismissal order stands, and Bazemore’s lawsuit against the union is terminated without prejudice to filing new claims if they fall within the statutory time limits or are supported by sufficient factual allegations. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.