McLane Co. v. Equal Emp't Opportunity Comm'n, 137 S. Ct. 1159

Ochoa, a former McLane employee, alleged sex discrimination after failing a physical evaluation required when returning from maternity leave and being fired; EEOC investigated her charge and later expanded to nationwide and age-discrimination inquiries.
The EEOC issued subpoenas to McLane seeking both basic evaluation data and "pedigree information" (names, SSNs, contact info) for employees who took the test; McLane produced anonymized data but refused pedigree data.
EEOC sought district-court enforcement of subpoenas after McLane declined to comply; the District Court refused to enforce subpoenas insofar as they sought pedigree information, finding the pedigree data not relevant.
The Ninth Circuit reversed, reviewing the District Court's relevance and undue-burden determinations de novo and holding the pedigree data relevant.
The Supreme Court granted certiorari to resolve whether appellate review of a district court's decision to enforce or quash an EEOC subpoena is de novo or for abuse of discretion.
The Supreme Court held that courts of appeals should review such district-court decisions for abuse of discretion, vacated the Ninth Circuit judgment, and remanded for reconsideration under the proper standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriate standard of appellate review for a district court's decision to enforce/quash an EEOC subpoena	(EEOC / intervenor) District-court enforcement decision should be reviewed de novo to ensure correct legal interpretation	(McLane) Deferential abuse-of-discretion review because decisions are fact-intensive and within district courts' institutional competence	Abuse of discretion is the proper standard of review
Whether pedigree information was relevant to EEOC's investigation	EEOC: pedigree info is relevant to nationwide pattern/impact and thus discoverable; mere relevance suffices	McLane: pedigree info not relevant; names/interviews would not show discrimination	Court did not decide on relevance on merits; remanded for Court of Appeals to apply abuse-of-discretion review (District Court could have erred as a matter of law)

University of Pennsylvania v. EEOC, 493 U.S. 182 (1990) (Title VII gives EEOC broad right of access to evidence and permits subpoena enforcement proceedings)
EEOC v. Shell Oil Co., 466 U.S. 54 (1984) (district courts should ensure charge validity and broad construction of "relevant" in EEOC subpoenas)
United States v. Morton Salt Co., 338 U.S. 632 (1950) (administrative subpoenas must not be unreasonable or too indefinite)
Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990) (abuse-of-discretion review does not protect decisions based on legal error)
Pierce v. Underwood, 487 U.S. 552 (1988) (framework for choosing appellate review standard: historical practice and institutional competence)
United States v. Nixon, 418 U.S. 683 (1974) (enforcement of subpoenas routinely reviewed under deferential standards)