The Court found that although the EEOC's regulations are not a picture of clarity in defining the statutory term "charge," they reasonably interpret statute and are therefore entitled to deference. To be considered a "charge," the document must embody a request by the employee for the agency to take whatever action is necessary to vindicate her rights.
The Court rejected the argument that the EEOC's failure to act on a filing meant it was not a charge. The Court did, however, admonish the EEOC to consider revising its forms and procedures to "reduce the risk of further misunderstandings."
Interestingly, Justice Thomas, who used to head the EEOC, dissented. In his dissent, joined by Justice Scalia, Thomas said the majority is essentially considering a charge to be "whatever [the EEOC] says it is." He said the standard is too "malleable" and that it "effectively absolves the EEOC of its obligation to administer the ADEA according to discernible standards."