Equal Employment Opportunity Commission v. Eberspaecher North America Inc., 67 F.4th 1124

Joseph White, an employee at Eberspaecher North America’s (ENA) Northport, AL plant, filed an EEOC charge alleging ADA/ADAAA discrimination for being disciplined/terminated after disability- and FMLA‑related absences; the Commissioner’s written charge named ENA with the Northport address.
The EEOC’s initial notices and requests were directed to the Northport facility and referenced the charge’s allegations and ENA’s employee handbook.
The EEOC later served a subpoena seeking nationwide records: lists and supporting documents for every employee terminated for attendance infractions at all seven U.S. ENA facilities, regardless of disability or FMLA status.
ENA objected, arguing the charge targeted only Northport and that nationwide production was overbroad and burdensome; EEOC sought enforcement in district court.
The district court enforced the subpoena only as to Northport records, concluding the charge’s four corners put ENA on notice of a Northport‑specific investigation and that nationwide data was not relevant to that charge.
The Eleventh Circuit affirmed, holding (1) the Commissioner’s charge reasonably read as limited to the Northport facility and (2) the nationwide subpoenaed information was not relevant to the Northport‑specific charge.

Issue	Plaintiff's Argument (EEOC)	Defendant's Argument (ENA)	Held
Whether the EEOC’s charge targeted ENA nationwide or only the Northport facility	Charge is nationwide (policy/handbook review and “all employees” language show companywide intent)	Charge names ENA with the Northport address; charge gave notice only of Northport investigation	Charge limited to Northport; inclusion of Northport address and notice directed there supported district court
Whether nationwide attendance‑termination data is relevant to a Northport‑specific charge	Nationwide data is relevant under a broad construction of "relevance" (shows companywide policy, identifies victims, distinguishes local manager vs policy)	Nationwide data is overbroad and not tied to issues needed to resolve the Northport charge	Not relevant; nationwide requests exceed scope of charge and would render "relevance" a nullity; subpoena enforced only for Northport
Whether the district court abused its discretion in partially enforcing the subpoena	Enforcement should have been nationwide; district abused discretion	District acted within discretion limiting enforcement to relevant scope	No abuse of discretion; Eleventh Circuit affirms partial enforcement

McLane Co., Inc. v. E.E.O.C., 137 S. Ct. 1159 (2017) (framework and standard for judicial review of EEOC subpoena enforcement)
E.E.O.C. v. Shell Oil Co., 466 U.S. 54 (1984) (EEOC entitled to broad access to materials "that might cast light" on allegations, but relevance requirement not toothless)
Univ. of Pa. v. E.E.O.C., 493 U.S. 182 (1990) (court’s role: ensure charge validity and material relevance in subpoena enforcement)
E.E.O.C. v. Royal Caribbean Cruises, Ltd., 771 F.3d 757 (11th Cir. 2014) (distinguishing individual charge from pattern‑or‑practice demands; relevance tied to issues to resolve that charge)
E.E.O.C. v. Kronos Inc., 620 F.3d 287 (3d Cir. 2010) (permitting broader discovery where EEOC explicitly expanded charge to nationwide facilities)