Landgraf v. USI Film Products
Citation: 511 U.S. 244 (U.S. Supreme Court, 1994)
Facts
Barbara Landgraf brought a sexual harassment claim against USI Film Products under Title VII of the Civil Rights Act of 1964. While her case was pending, Congress enacted the Civil Rights Act of 1991, which for the first time authorized compensatory and punitive damages for Title VII claims. Her conduct predated the 1991 Act, and the question was whether the new damages provisions applied to her pending case.
Issue
Do the newly enacted compensatory and punitive damages provisions of the Civil Rights Act of 1991 apply to cases in which the underlying conduct occurred before the Act’s enactment?
Holding
The Court (7–2, Stevens, J.) held that the 1991 Act’s damages provisions did not apply retroactively to Landgraf’s pending case because Congress had not clearly expressed retroactive intent.
Rule
There is a strong presumption against retroactivity in statutory interpretation: a statute is presumed to apply only prospectively unless Congress has clearly indicated retroactive effect. Courts apply a two-step framework: (1) did Congress expressly provide for retroactivity? (2) if not, would applying the statute attach new legal consequences to completed conduct — if so, the presumption against retroactivity controls and the statute is applied only prospectively.
Significance
Landgraf is the leading case on the presumption against retroactivity as a statutory default rule. The opinion provides a thorough account of why retroactivity raises rule-of-law concerns (notice, reliance, fairness) and how courts should determine whether a statute applies to pending cases. It pairs with Rivers v. Roadway Express (decided the same day) and is central to any course on statutory defaults and background presumptions in interpretation.