McLane Co. v. Equal Employment Opportunity Commission

After Damiana Ochoa left her job at McLane Company, she filed a sex discrimination charge with the EEOC. During its investigation, the EEOC issued an administrative subpoena demanding personal information of other employees, including names and Social Security numbers. McLane refused to comply, arguing the information was irrelevant. The District Court declined to fully enforce the subpoena. The Ninth Circuit reversed, applying de novo review. The Supreme Court granted certiorari to resolve a circuit split on the proper standard of appellate review for such decisions.

In a unanimous decision delivered by Justice Sotomayor, the Supreme Court held that a district court's ruling on an EEOC subpoena enforcement petition is reviewed for abuse of discretion, not de novo. The judgment of the Ninth Circuit was vacated and the case remanded.

Whether a district court's decision to enforce or quash an EEOC administrative subpoena should be reviewed on appeal de novo or under the more deferential abuse-of-discretion standard.

The ruling resolved a long-standing circuit split, reinforcing the discretionary authority of district courts in managing administrative subpoenas. It made it harder for appellate courts to second-guess trial court determinations of relevance and burden, thereby providing greater certainty for employers and agencies engaged in discrimination investigations.