EEOC v. Sterling Jewelers, Inc., No. 14-1782 (2d Cir. 2015)
Annotate this CaseThe EEOC filed suit against Sterling under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., alleging that Sterling engaged in a nationwide practice of sex‐ based pay and promotion discrimination. The magistrate judge issued a Report and Recommendation finding after conducting discovery and found that the EEOC failed to prove that it satisfied its statutory obligation to conduct a pre‐suit investigation and recommended summary judgment on that basis. The district court adopted the Report and Recommendation, granting summary judgment to Sterling. The court concluded, however, that the district court erred in granting summary judgment because the magistrate judge improperly reviewed the sufficiency of the EEOC investigation rather than whether there was an investigation. Under Title VII, courts may review whether the EEOC conducted an investigation, but not the sufficiency of an investigation. Because the EEOC conducted an investigation in this case, the court vacated the summary judgment order and remanded for further proceedings.
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