Equal Employment Opportunity Commission v. Randstad
685 F.3d 433
4th Cir.2012Background
- Morrison, Jamaican; illiterate in reading/writing English; filed EEOC charge alleging literacy-based termination violated Title VII.
- Randstad placed Morrison in industrial assignments; two early placements ended quickly for performance, unaware of his illiteracy.
- In Sept. 2006, Morrison was told Randstad does not hire non-readers and would place him again only after literacy improvement; his assignment ended.
- EEOC subpoenaed Randstad for broad records about Maryland positions 2005–2009; Randstad objected as unduly burdensome and irrelevant to Morrison’s claims.
- Morrison later filed an amended EEOC charge (Jan. 2009) asserting ADA disability discrimination; district court denied enforcement of the subpoena; EEOC appealed.
- This appeal addresses EEOC authority and the subpoena’s relevance under Title VII and the ADA, and whether the burden was undue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ADA charge relates back to the original charge. | Morrison’s amended ADA claim relates back under §1601.12(b) as clarification/amplification of the original factual allegations. | Relating back would undermine timely notice and raises whether amendment changes the theory. | Yes; amended ADA charge relates back to original filing date. |
| Whether Title VII authority remained after the amended ADA charge. | Original Title VII charge continued to trigger investigation despite ADA amendment. | Original Title VII allegations were altered/omitted; ADA authority suffices. | Yes; EEOC had authority under Title VII to pursue relevant information. |
| Whether the subpoena materials were relevant to Morrison’s charges. | Materials about all Maryland positions illuminate whether literacy is universally required. | Only materials tied to Morrison’s specific placements matter; broader data unnecessary. | Yes; materials were within the broad relevance standard for EEOC investigations. |
| Whether the cost burden renders enforcement unduly burdensome. | Costs ( ~$14k–$19k) were not shown to unduly disrupt Randstad’s operations. | Compiling data would be burdensome; cost justification supports non-enforcement. | No; burden not shown as undue under Maryland Cup precedent. |
Key Cases Cited
- Edelman v. Lynchburg College, 535 U.S. 106 (U.S. 2002) (upheld EEOC regulation deference in relation-back context)
- Shell Oil Co. v. United States, 466 U.S. 54 (U.S. 1984) (EEOC investigations broad relevance standard; defer to agency judgment)
- Maryland Cup Corp., 785 F.2d 471 (4th Cir. 1986) (burden-of-production and enforceability standards for subpoenas)
- Evans v. Tech. Applications & Serv. Co., 80 F.3d 954 (4th Cir. 1996) (context for relation back of amended charges; distinguishable facts here)
- Auer v. Robbins, 519 U.S. 452 (U.S. 1997) (deference to agency interpretation of regulations)