EEOC v. Arabian American Oil Co. (Aramco)
Citation: 499 U.S. 244 (1991) Court: Supreme Court of the United States
Facts
Ali Boureslan, an American citizen of Lebanese origin, was employed in Saudi Arabia by Aramco, a Delaware corporation. He was discharged and filed a charge with the EEOC alleging national-origin discrimination under Title VII of the Civil Rights Act of 1964. The EEOC argued Title VII applied to American citizens working abroad for American employers; Aramco contended Title VII had no extraterritorial reach.
Issue
Whether Title VII of the Civil Rights Act of 1964 applies to American employers’ treatment of American employees working outside the United States.
Holding
The Supreme Court (5-4) held that Title VII did not apply extraterritorially. The Court found that Congress had not clearly expressed an intent to extend Title VII’s protections beyond U.S. borders.
Rule / Doctrine
The presumption against extraterritoriality: absent a clear statement from Congress, federal statutes are presumed to apply only within the territorial jurisdiction of the United States. Courts will not infer extraterritorial application from general statutory language; Congress must speak clearly if it intends a statute to reach conduct occurring abroad. This canon is applied at the time of enactment, based on the text and context of the statute as passed.
Significance
EEOC v. Aramco is the leading case establishing the modern presumption against extraterritoriality as a canon of statutory construction. Congress promptly overruled the decision by enacting the Civil Rights Act of 1991, which amended Title VII to expressly cover American employees of American employers working abroad. The case is frequently taught alongside Morrison v. National Australia Bank (2010) and RJR Nabisco v. European Community (2016), which apply and refine the presumption in other contexts.