...court; rather, it is like a statute of limitations and is thus subject to the doctrines of "waiver, estoppel, and equitable tolling." 455 U.S. at...public employer, the timely filing of a lawsuit is not a jurisdictional requirement but (again) is a precondition, like a statute of limitations, that is subject to equitable tolling. In 1994 and 1996, this court applied the same rationale as in Rennie and held that the intermediate and initial time limits for filing administrative complaints, respectively, are not jurisdictional requirements but are preconditions subject to the doctrines of equitable...jurisdictional, but rather is like a statute of limitations, in that it is subject to waiver, estoppel and equitable tolling."
Pack involved Title VII while Charlie F. concerned...