McLane Co. v. EEOC, 197 L. Ed. 2d 500

Damiana Ochoa, a long‑time McLane employee, failed a required physical evaluation after maternity leave and was terminated; she filed a sex‑discrimination charge with the EEOC.
The EEOC investigated and requested employee “pedigree” data (names, SSNs, addresses, phone numbers) for those given the evaluation; McLane refused to produce pedigree information.
The EEOC expanded its inquiry nationwide and to include age discrimination, issued subpoenas under Title VII, and sought district court enforcement when McLane continued to refuse.
The district court quashed enforcement as to pedigree information, finding it not relevant to the charges; the Ninth Circuit reversed under de novo review.
The Supreme Court granted certiorari to resolve whether appellate review of a district court’s decision to enforce or quash an EEOC subpoena should be de novo or for abuse of discretion and held abuse of discretion is the proper standard; the Ninth Circuit judgment was vacated and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriate standard of appellate review for district court enforcement/quash of an EEOC subpoena	(EEOC) District court decisions should be reviewed de novo to ensure legal correctness	(McLane) Review for abuse of discretion because district courts make fact‑intensive, case‑specific judgments	Abuse of discretion is the proper standard
Whether pedigree information was relevant enough to justify enforcement	EEOC: relevance is broadly construed; pedigree info could identify witnesses and shed light on discrimination patterns	McLane: names and contact info would not show whether the evaluation is discriminatory; burden and privacy concerns	Court did not resolve merits; remanded for the court of appeals to apply abuse‑of‑discretion review and consider burden arguments
Role of district court in enforcement proceedings	EEOC: district court should ensure charge is valid and material is relevant, with generous view of relevance	McLane: district court should test legal sufficiency and protect against undue burden and indefiniteness	District court must assess validity and relevance (generously construed) and whether subpoena is indefinite, illegitimate, or unduly burdensome

Pierce v. Underwood, 487 U.S. 552 (standard‑of‑review framework; consider history and institutional competence)
University of Pa. v. EEOC, 493 U.S. 182 (Title VII gives EEOC broad access to relevant evidence and outlines district court’s limited role)
EEOC v. Shell Oil Co., 466 U.S. 54 (relevance construed generously; access to material casting light on allegations)
Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (abuse‑of‑discretion principles; appellate deference to district factfinding)
Oklahoma Press Pub. Co. v. Walling, 327 U.S. 186 (relevance assessment varies with nature and scope of inquiry)
United States v. Morton Salt Co., 338 U.S. 632 (subpoena must not be unreasonable or too indefinite)
United States v. Nixon, 418 U.S. 683 (subpoena enforcement reviewed with deference in some contexts)
Illinois v. Gates, 462 U.S. 213 (approach to fact‑intensive inquiries and deference considerations)
Ornelas v. United States, 517 U.S. 690 (distinguished; not every Fourth Amendment‑adjacent question requires de novo review)
Buford v. United States, 532 U.S. 59 (district courts’ institutional advantages support deference)
Sprint/United Mgmt. Co. v. Mendelsohn, 552 U.S. 379 (subpoena burdens are fact‑intensive and not amenable to per se rules)