McLane Co. v. Equal Employment Opportunity Commission

Ochoa worked in a physically demanding job for McLane, which requires new employees in such positions and those returning from medical leave to take a physical evaluation. When Ochoa returned from three months of maternity leave, she failed the evaluation three times and was fired. She filed a sex discrimination charge under Title VII of the Civil Rights Act. The Equal Employment Opportunity (EEOC) began an investigation, but McLane declined its request for names, Social Security numbers, addresses, and telephone numbers of employees asked to take the evaluation. After the EEOC expanded the investigation’s scope, it issued subpoenas under 42 U.S.C. 2000e–9, requesting information relating to its new investigation. The district judge declined to enforce the subpoenas. The Ninth Circuit reversed, holding that the lower court erred in finding the information irrelevant. The Supreme Court vacated. A district court’s decision whether to enforce or quash an EEOC subpoena should be reviewed for abuse of discretion, not de novo. The Court noted “the longstanding practice of the courts of appeals," to review a district court’s decision to enforce or quash an administrative subpoena for abuse of discretion. In most cases, the enforcement decision will turn either on whether the evidence sought is relevant to the specific charge or whether the subpoena is unduly burdensome under the circumstances. Both tasks are well suited to a district judge’s expertise. Deferential review “streamline[s] the litigation process by freeing appellate courts from the duty of reweighing evidence and reconsidering facts already weighed and considered by the district court,” something particularly important in a proceeding designed only to facilitate the EEOC’s investigation. Not every decision touching on the Fourth Amendment is subject to searching review. View "McLane Co. v. Equal Employment Opportunity Commission" on Justia Law