McLane Co. v. EEOC

A court of appeals should review a district court’s decision to enforce or quash an Equal Employment Opportunity Commission subpoena for an abuse of discretion.

Petitioner’s employee returned from maternity leave, failed a physical evaluation, and was fired. The employee then filed a charge of discrimination on the grounds that she had been fired based on her gender. Respondent then began its investigation into the allegation and requested information from Petitioner as to which employees had been made to take the evaluation. Petitioner provided basic information, except for the employees’ “pedigree information.” When Respondent attempted to acquire the information through a subpoena but Petitioner refused. Respondent then filed an action in federal district court to enforce its subpoena. The district court denied enforcement because it found the “pedigree information” to be irrelevant to the allegations. Respondent appealed and the Ninth Circuit, under a de novo standard of review, reversed after determining that the district court had erred when it found that the information was irrelevant. The United States Supreme Court granted certiorari in order to clarify the correct standard of review. After finding no statutorily explicit command, the Court applied the test in Pierce v. Underwood and determined that the district court’s decision should have been reviewed for an abuse of discretion. Under that analysis, the Court determined that the “history of appellate practice” showed that the decision regarding an administrative subpoena should be reviewed for an abuse of discretion. Moreover, the Court also determined that because this issue was case-specific, the standard should be deferential to the court’s expertise. VACATED and REMANDED.