McLane Co. v. EEOC

Background

Damiana Ochoa, a woman who worked as a cigarette selector, was fired after failing a physical evaluation when she returned from maternity leave. The employer, McLane, refused the EEOC’s request for employees’ names and contact details (“pedigree information”), so the EEOC issued subpoenas and sued in district court to enforce them. The district judge declined to enforce the subpoenas for pedigree information, the Ninth Circuit reversed, and the Supreme Court took the case to decide how appeals courts should review such enforcement decisions.

Reasoning

The Court addressed whether an appeals court should review de novo or for abuse of discretion a district court’s decision to enforce or quash an EEOC subpoena. Relying on the long history of deferential review and on the practical judgment that district judges are better placed to resolve fact-based questions about relevance and burden, the majority held that abuse-of-discretion review applies. The Court explained that legal errors remain reviewable because a decision is an abuse of discretion if based on an incorrect view of the law. The Court vacated the Ninth Circuit’s judgment and remanded for reconsideration under the proper standard.

Real world impact

The ruling means that appeals courts will generally defer to district judges’ decisions about whether requested documents relate to an EEOC investigation and whether producing them is unduly burdensome. That makes it harder for parties to get a quick reversal of a district court’s subpoena determination. The EEOC keeps its broad subpoena power, but enforcement fights will be decided first by district judges and then reviewed deferentially.

Dissents or concurrances

Justice Ginsburg agreed the abuse-of-discretion standard usually applies but would have affirmed the Ninth Circuit here, saying the district court wrongly required more than mere relevance.