Term: 2014
Docket: 13-1019
Mach Mining, Llc, v. Equal Employment Opportunity Commission
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13-1019 MACH MINING, LLC V. EEOC DECISION BELOW: 738 F.3d 171 CERT. GRANTED 6/30/2014 QUESTION PRESENTED: In Title VII of the Civil Rights Act of 1964, "Congress established an integrated, multistep enforcement procedure culminating in the EEOC's authority to bring a civil action in federal court." Occidental Life Ins. Co. v. EEOC, 432 U.S. 355, 359 (1977). At the outset of that process, if the EEOC finds that there is reasonable cause to believe a charge of discrimination against a private party it "shall endeavor to eliminate any ... alleged unlawful employment practice by informal methods of conference, conciliation, and persuasion." 42 U.S.C. § 2000e-5(b). The Commission is forbidden from filing suit unless within a specified period it "has been unable to secure from the respondent a conciliation agreement acceptable to the Commission." Id. § 2000e-5(f)(1). Congress imposed similar requirements in the Age Discrimination in Employment Act, 29 U.S.C. § 626(b), the Fair Housing Act, 42 U.S.C. § 3610(b)(1), and federal election law, 2 U.S.C. §§ 437g(a)(4), (a)(6)(A). The Question Presented, on which the Seventh Circuit in this case avowedly rejected the precedent of numerous other courts of appeals, is: Whether and to what extent may a court enforce the EEOC's mandatory duty to conciliate discrimination claims before filing suit? LOWER COURT CASE NUMBER: 13-2456
The U.S. Supreme Court case Mach Mining, LLC v. Equal Employment Opportunity Commission (EEOC) in 2014 revolved around the EEOC's duty to attempt conciliation before filing a lawsuit against an employer for alleged discrimination. The court ruled unanimously that courts have the authority to review whether the EEOC has fulfilled its obligation under Title VII of the Civil Rights Act of 1964 to negotiate in good faith with employers accused of discrimination before resorting to litigation. However, it also held that this review is limited and highly deferential towards the EEOC’s judgment on what constitutes satisfactory negotiation efforts. This ruling clarified how far-reaching judicial oversight should be over administrative agencies' pre-litigation procedures while balancing their discretion and expertise.
In the case of Mach Mining, LLC v. Equal Employment Opportunity Commission (EEOC), there was no dissenting opinion recorded by any justice. The Supreme Court unanimously ruled in favor of EEOC, stating that its conciliation efforts are subject to judicial review but also setting limits on what that review entails. This means all justices agreed with the decision and hence no one wrote a dissenting opinion against it.
