Equal Employment Opportunity Commission v. Care Centers Management Consulting, Inc., 942 F. Supp. 2d 771

EEOC filed a 2012 complaint on behalf of Doe alleging ADA/ADAAA and Civil Rights Act violations based on HIV disability.
CCMC and Christian Care Center of Johnson City are alleged to operate as a single employer/integrated enterprise with shared ownership/management.
The EEOC claims CCMC and Christian Care share management, address, and centralize labor relations, with 1-800-615-CARE directed to CCMC.
Doe’s charge names only Christian Care as the respondent, not CCMC, raising jurisdictional and notice issues.
The court must resolve whether the “single employer” or “integrated enterprise” theory sustains CCMC’s liability and whether dismissal or summary judgment is appropriate.
The court ultimately denies CCMC’s Rule 12(b)(1)/(b)(6) motions and denies summary judgment as premature, lifting the stay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has subject matter jurisdiction despite not naming CCMC in the charge.	Identity of interest between CCMC and Christian Care allows suit.	Lack of adequate notice and failure to name CCMC bars jurisdiction.	Denial of CCMC’s 12(b)(1) motion; identity of interest found.
Whether EEOC plausibly pleaded CCMC as a ‘single employer’/‘integrated enterprise.’	Facts show interrelated operations, management, and control.	Facts insufficient to establish single employer status.	Denial of CCMC’s 12(b)(6) motion; complaint plausibly states a theory.
Whether the court should convert to summary judgment under Rule 56.	Discovery needed to oppose; stay should remain.	Court may convert and decide now.	Denial as premature; discovery to proceed; stay lifted.
Whether the identity-of-interest analysis satisfies the four-factor Swallows/Glus tests.	Facts satisfy interrelation, common management, centralized control, and ownership.	Examples insufficient in isolation; lack of complete factors.	Court finds sufficient plausibility under Swallows/Glus to proceed.

Eggleston v. Chicago Journeymen Plumbers’ Local Union No. 130, 657 F.2d 890 (7th Cir. 1981) (identifying conditions for identity of interest in EEOC context)
Swallows v. Barnes & Noble Book Stores, Inc., 128 F.3d 990 (6th Cir. 1997) (single-employer factors for interrelated entities)
Glus v. G.C. Murphy Co., 562 F.2d 880 (3d Cir. 1977) (multi-factor test for identity of interest in EEOC proceedings)
Jones v. Truck Drivers Local Union No. 299, 748 F.2d 1083 (6th Cir. 1984) (naming/identity-of-interest precedent for EEOC charges)
York v. Tennessee Crushed Stone Ass’n, 684 F.2d 360 (6th Cir. 1982) (four-factor approach to single-employer inquiry)
Romain v. Kurek, 836 F.2d 241 (6th Cir. 1987) (identity-of-interest exception to charging-name requirement)