Procedural History
Damiana Ochoa had taken a maternity leave and upon her return was notified by her employer, McLane Company that she needed to pass a test of her physical capabilities before she could reclaim her position. According to Ochoa, the procedure was a company policy. However, Ochoa failed the test thrice and her contract was thus terminated. Equal Employment Opportunity Commission (E.E.O.C.) decided to investigate gender discrimination allegations against McLane Company. McLane offered some information to E.E.O.C. to help in the case. However, the company withheld some information. The commission thus sought for an administrative subpoena that was meant to compel the company to offer the information that had not been revealed. However, the district court declined to enforce a portion of the subpoena. It resulted in E.E.O.C. appealing the decision at the Ninth Circuit Court of Appeal for them to access the information that was being withheld. The Ninth Circuit reviewed the E.E.O.C’s request de novo, which involved not giving a consideration to the decision made by the district court. The Ninth Circuit went ahead to review the administrative categories of information that the E.E.O.C issued a subpoena.
Facts of the Case
Damiano Ochoa had filed a charge with the E.E.O.C following his dismissal from her place of employment, McLane Company, after she failed to pass three fitness tests that were administered after her maternity leave. According to Ochoa, the company had violated Title VII of the Civil Rights Act that was passed in 1964. McLane had a company policy that required all newly employed workers and the employees that were coming back from medical leave to undergo a physical capability physical strength test. The tests were required for positions considered to be physically demanding. Ochoa underwent the test unsuccessfully three times and this led to her determination. Upon filing of the charge, the E.E.O.C. commenced its investigations. McLane provided some information but withheld some leading to E.E.O.C. Issuing a subpoena for the information that had been withheld. The company continued to withhold the information leading E.E.O.C. to file for an enforcement action for the subpoena. The district court made a ruling that McLane should disclose some information for which the E.E.O.C. had subpoenaed. The district court declined to force McLane to provide information on reasons for termination. Upon appeal to the Ninth Circuit Court of Appeals by E.E.O.C., the decision by the district court was reversed partially and reviewed in part after a review was done de novo (US Court of Appeals for the Ninth Circuit, 2015) .
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Issues
"Whether a district court's decision to quash or enforce an EEOC subpoena should be reviewed de novo , which only the Ninth Circuit does, or should be reviewed deferentially, which eight other circuits do, consistent with this Court's precedents concerning the choice of standards of review" (Supreme Court of the United States, 2016).
Holding
The court determined that the most appropriate standard involved in a review of the decision made by the district court, on whether to quash or enforce an E.E.O.C subpoena on appeal, entailed reviewing the decision to establish if the court was involved in an abuse of judicial discretion as opposed to reviewing the request for a subpoena as if the district court did not make any judgement regarding the subpoena request; that is what entails reviewing the decision de novo. The Supreme Court thus vacated and remanded the judgement that was made by the appellate courts.
Court Rationale
The court determined the appellate courts abused their discretion standard when reviewing the decision of the district court. It failed to review the case under the correct standards since it reviewed the subpoena request instead of establishing whether an abuse of judicial discretion by the district court.
Analysis
The ruling in the case highlighted instances of misuse of standard procedures in appellate courts when determining cases from lower courts. The ruling thus influenced the courts to be more observant on their use of standard procedures in determining cases. The ruling has impacted on the government and citizens as it highlights an instance of wrong use of standard procedures by the court. The government and citizens will be more emboldened to appeal cases up to the highest courts since they are aware that the courts can sometimes base their rulings on wrong procedures. I agree with the analysis of the court. The appellate courts used a standard procedure in the wrong way by reviewing the subpoena request instead of establishing an abuse of judicial discretion.
References
Supreme Court of the United States, McLane Co. v. EEOC, September 29, 2016
U.S. Court of Appeals for the Ninth Circuit, U.S. Equal Employment Opportunity Commission v. McLane Company, Inc., October 27, 2015 .
