Equal Employment Opportunity Commission v. Konica Minolta Business Solutions U.S.A., Inc.
2011 U.S. App. LEXIS 8894
| 7th Cir. | 2011Background
- Thompson, an African-American salesman at Konica, was fired after ~8 months (Oct 2005).
- Thompson filed an EEOC charge alleging race-based terms/conditions, discipline, and termination.
- EEOC investigated and subpoenaed Konica’s Chicago-area hiring records in 2008; Konica resisted as irrelevant to Thompson’s charge.
- EEOC sought hiring/selection data for four Chicago-area facilities, focusing on race of applicants and outcomes.
- District court ordered enforcement of the subpoena in 2009; Konica appealed to the Seventh Circuit.
- EEOC argued the subpoena sought information relevant to potential discriminatory practices and pattern-or-practice considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the subpoena is relevant to Thompson’s charge under Title VII | EEOC contends hiring data illuminates discrimination patterns linked to Thompson’s claim | Konica contends data on hiring at other branches is irrelevant to Thompson’s charge | Yes; subpoena is relevant to investigation of Thompson and potential pattern of discrimination. |
| Whether the EEOC’s scope was properly limited to four branches and sales personnel | Investigative authority extends to related employment practices within the agency’s jurisdiction | Limited scope would undermine broader investigation | Properly tailored to four Chicago-area branches and sales personnel. |
| Whether the EEOC’s subpoena complies with Shell Oil standard of relevance | Subpoena advances investigation into possible systematic discrimination | Requests are too broad/unnecessary | Satisfied; information reasonably calculated to lead to admissible evidence. |
| Whether the subpoena constitutes an undue burden | Burden must be shown and outweighed by public interest | Unpersuasive; presumption in favor of compliance stands. |
Key Cases Cited
- Shell Oil Co. v. Occupational Safety & Health Admin., 466 U.S. 54 (U.S. 1984) (broad relevance standard for EEOC subpoenas; investigation scope to systemic discrimination)
- EEOC v. United Air Lines, Inc., 287 F.3d 643 (7th Cir. 2002) (subpoena enforcement and relevance standards; high deference to agency investigations)
- EEOC v. Tempel Steel Co., 814 F.2d 482 (7th Cir. 1987) (summary nature of subpoena enforcement proceedings; criteria for enforcement)
- Chaney v. Plainfield Healthcare Center, 612 F.3d 908 (7th Cir. 2010) (customer considerations not a defense to race-based employment decisions)
- United States v. Arthur Young & Co., 465 U.S. 805 (U.S. 1984) (reasonableness of discovery under Rule 26 analogue; admissibility not required for relevance)