EEOC v. Randstad, No. 11-1759 (4th Cir. 2012)
Annotate this CaseKevin Morrison, a resident of Maryland, was born in Jamaica and cannot read or write English. He filed a charge of discrimination with the Equal Employment Opportunity Commission ("EEOC") asserting that Appellee Randstad terminated his employment pursuant to a requirement that its employees read and write English. Two years later, in an amended charge, Morrison asserted that the literacy policy violated the Americans with Disabilities Act (ADA) because he has a learning disability. In investigating Morrison’s charges, the EEOC served an administrative subpoena on Randstad, which Randstad resisted, in part. When the EEOC sought judicial enforcement of its subpoena, the district court denied relief. "Once a charge has placed the Commission on notice that a particular employer is (or may be) violating Title VII or the ADA in a particular way, the Commission may access 'virtually any material that might cast light on the allegations against the employer.'" The question was whether and to what extent these materials were "relevant" to the EEOC’s investigation of Morrison’s charges. The district court concluded that none of the requested materials were relevant. Upon review, the Fourth Circuit concluded that the district court’s application of an unduly strict standard of relevance amounted to legal error, leading to an abuse of discretion. Applying the correct standard, with deference to the EEOC’s assessment of relevance, the Court concluded that all of the EEOC’s requested materials fell within the broad definition of relevance applicable to EEOC administrative subpoenas, and that the district court’s rejection of the EEOC’s alleged factual nexus "crossed the line" into an assessment of the merits of Morrison’s claim. The Fourth Circuit reversed the district court's decision and remanded the case for further proceedings.
The court issued a subsequent related opinion or order on July 24, 2012.
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