Equal Emp't Opportunity Comm'n v. CRST Van Expedited, Inc., No. 13-3159 (8th Cir. 2014)
Annotate this CaseEEOC sued CRST in its own name, under Title VII, 42 U.S.C. 2000e, alleging that CRST subjected Starke and 270 similarly situated female employees to a hostile work environment, in its Driver Training Program. For two years, EEOC failed to identify the women comprising the putative class; the court ordered EEOC to make all class members available for deposition or risk a discovery sanction. EEOC filed updated lists of allegedly aggrieved individuals, but failed to make all of them available for deposition before the deadline. The court barred EEOC from pursuing relief for any individual not made available for deposition before the deadline. EEOC then listed 155 individuals for whom it was still pursuing relief and 99 individuals, allegedly sexually harassed, but for whom EEOC was not pursuing relief based on the order. Following remand, the court dismissed, but for one claim, which settled for $50,000, and awarded CRST $92,842.21 in costs, $4,004,371.65 in attorneys' fees, and $463,071.25 in out-of-pocket expenses. The Eighth Circuit held that CRST is not entitled to attorneys' fees for claims dismissed based on EEOC's failure to satisfy pre-suit obligations and a purported pattern-or-practice claim. On remand, the court must individually assess each claim for which it granted summary judgment on the merits and explain why it deems each to be frivolous, unreasonable, or groundless.
Court Description: Civil case - Attorneys' fees. For the court's prior opinion in the matter, see EEOC v. CRST Van Expedited, 679 F.3d 657 (8th Cir. 2012). Appeal of an order granting CRST more than $4.6 million in attorneys' fees, costs and expenses. Where the district court dismissed 67 of the EEOC's claims for failure to satisfy Title VII's presuit obligations, that dismissal was not a ruling on the merits and CRST was not a prevailing party on those claims and was not entitled to an award of attorneys' fees on the claims; nor was CRST entitled to an award regarding dismissal of the EEOC's purported pattern-or-practice claim; a prevailing Title VII defendant is not entitled to attorneys' fees unless the court determines the plaintiff's claims were frivolous, unreasonable or groundless; here the district court did not make such particularized findings with respect to the remaining counts brought by the EEOC, and the case must be remanded for such findings on these counts; the same analysis applies to costs associated with the EEOC's appeal. Reversed and remanded for further proceedings.
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