In Ransom v. United States Postal Service, the EEOC had granted relief on plaintiff's individual discrimination claim. Later, after she filed class claims on behalf of disabled postal workers, the EEOC stated that she had to seek class counseling. Finding that plaintiff had not done so witin the forty- five day period allowed, the district court dismissed the complaint. On Feb. 10 the Tenth Circuit affirmed, noting that "[f]ederal courts do not have jurisdiction to review Title VII and ADA claims not exhausted administratively" and held that plaintiff's failure to seek class counseling was a failure to exhaust those claims. The court also held that claims should be dismissed because a pro se cannot litigate on behalf of a class.- A.S.