On August 1, 2013, the United States District Court for the Northern District of Iowa ordered the Equal Employment Opportunity Commission (“EEOC”) to pay CRST Van Expedited, Inc. (“CRST”) a total of $4.7 million dollars in attorneys’ fees and expenses relating to the EEOC’s failed Title VII cases against the Company.
This matter began in September 2007 when the EEOC filed a Complaint on behalf of Monika Starke and a “class of similarly situated female employees of [CRST]” to “correct unlawful employment practices on the basis of sex.” The EEOC sought to represent a class of 270 women who were subject to CRST’s allegedly discriminatory policies. In April 2009, the District Court dismissed the pattern or practice claim asserted on behalf of the class and held that CRST would be liable only to the extent that the EEOC could prove individual sexual harassment claims.
In subsequent proceedings, the District Court dismissed all of the individual claims for a variety of reasons. Several claims were dismissed because they were barred by the statute of limitations. Other claims were dismissed because the court determined that they were frivolous. The court dismissed 67 claims because the EEOC failed to investigate each individual’s claim and make a reasonable cause determination as to their specific allegations. On appeal, the Eighth Circuit reversed the District Court’s grant of summary judgment with respect to two women. The EEOC later voluntarily withdrew the claim for one of the women and reached a settlement with CRST for the sole remaining claimant.
In March 2013, CRST filed a Bill of Costs and a Motion for Attorneys’ Fees. The District Court awarded CRST attorneys’ fees and expenses, concluding that: (1) CRST was a prevailing party pursuant to 42 U.S.C. § 2000e-5(k); (2) the EEOC’s claims were frivolous, unreasonable, and without foundation; and (3) the amount of attorneys’ fees sought by CRST, with minor exceptions, was reasonable. In total, the District Court awarded CRST $4.7 million dollars of attorneys’ fees, costs, and out-of-pocket expenses.
The fee award has been cited as one of the largest, if not the largest, fee award ever issued against the EEOC. In recent years, the EEOC stepped up its enforcement efforts by aggressively investigating and litigating instances of alleged workplace discrimination. Although it is too early to tell, this large fee award may induce the EEOC to more carefully scrutinize cases before pursuing expensive, large-scale complaints.