EEOC v. AAM Holding Corp.

CourtCourt of Appeals for the Second Circuit
DecidedAugust 25, 2025
Docket24-1672
StatusPublished

This text of EEOC v. AAM Holding Corp. (EEOC v. AAM Holding Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EEOC v. AAM Holding Corp., (2d Cir. 2025).

Opinion

24-1672-cv EEOC v. AAM Holding Corp.

United States Court of Appeals For the Second Circuit August Term, 2024

(Argued: March 24, 2025 Decided: August 25, 2025)

Docket No. 24-1672-cv _____________________________________

IN RE: AAM HOLDING CORP. -----------------

UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, (EEOC),

Applicant-Appellee,

v.

AAM HOLDING CORP., AGENT OF FLASHDANCERS GENTLEMEN’S CLUB, 59 MURRAY STREET ENTERPRISES, INC., AGENT OF FLASHDANCERS GENTLEMEN’S CLUB,

Respondents-Appellants. _____________________________________ Before:

CABRANES, LOHIER, SULLIVAN, Circuit Judges.

Eunice Raquel Flores Thomas, a former dancer at two adult clubs in New York City, filed a class charge with the Equal Employment Opportunity Commission (“EEOC”) alleging widespread sexual harassment and a hostile work environment at the clubs. The EEOC issued administrative subpoenas seeking pedigree information for the clubs’ employees and later petitioned to enforce the subpoenas. The United States District Court for the Southern District of New York (Lorna G. Schofield, Judge) granted the petition, and the clubs appealed. While this appeal was pending, the EEOC issued a right-to-sue letter to Thomas, who promptly filed suit against the clubs. The clubs argue that Thomas’s suit divests the EEOC of authority to investigate and enforce its subpoenas. They also claim that the subpoenas are overbroad and unduly burdensome. We hold that the EEOC retains its statutory investigative authority after it issues a right-to-sue letter and the charging party files a separate suit. Moreover, the pedigree information the EEOC seeks from the clubs is relevant to the underlying charge, and complying with the subpoenas would not be unduly burdensome in this case. We therefore AFFIRM.

JAMES DRISCOLL-MACEACHRON (Karla Gilbride, General Counsel, Jennifer S. Goldstein, Associate General Counsel, Dara S. Smith, Assistant General Counsel, on the brief), Equal Employment Opportunity Commission Office of General Counsel, Washington, DC, for Applicant-Appellee.

JEFFREY A. KIMMEL (M. Adil Yaqoob, on the brief), Akerman LLP, New York, NY, for Respondents- Appellants.

LOHIER, Circuit Judge:

Title VII of the Civil Rights Act of 1964 tasks the Equal Employment

Opportunity Commission (“EEOC”) with investigating charges filed by

aggrieved employees to “determine whether there is reasonable cause to believe

that [the charge] is true.” Occidental Life Ins. Co. of Cal. v. EEOC, 432 U.S. 355, 359

(1977). Congress gave the EEOC the “[p]rimary responsibility for enforcing Title

VII” through investigations, conciliation, and, where appropriate, civil litigation.

2 EEOC v. Shell Oil Co., 466 U.S. 54, 61–62 (1984); see 42 U.S.C. § 2000e-5(b), (f)(1).

But Congress “did not transfer all private enforcement to the EEOC.” Gen. Tel.

Co. of the Nw., Inc. v. EEOC, 446 U.S. 318, 326 (1980). “[T]he aggrieved person

may bring his own action at the expiration of [a] 180-day period of exclusive

EEOC administrative jurisdiction if the agency” declines to dismiss the charge or

file its own civil action, or fails to resolve the dispute by conciliation. Id. In that

case, the EEOC issues a right-to-sue letter to the aggrieved party, who is then

authorized to sue within 90 days. See 42 U.S.C. § 2000e-5(f)(1); 29 C.F.R.

§ 1601.28(a), (e).

The primary question presented by this appeal is whether the EEOC

retains the authority to investigate a charge even after it issues a right-to-sue

letter to the charging party and the charging party files a lawsuit. We hold that it

does. We further conclude that the information the EEOC requests here is

relevant to the underlying charge and that the Respondents have failed to show

that complying with the subpoenas is unduly burdensome. We accordingly

AFFIRM the order of the United States District Court for the Southern District of

New York (Lorna G. Schofield, Judge).

I

3 Eunice Raquel Flores Thomas is a former dancer at FlashDancers Midtown

and FlashDancers Downtown, two adult entertainment clubs operated by the

Respondents in Manhattan. Thomas worked “interchangeably at both locations”

from September 2019 to July 2021. App’x 6.

In March 2022 Thomas filed a class charge with the EEOC, alleging

widespread sexual harassment and a hostile work environment at both clubs,

which she claimed was “perpetuated through the policies and practices” of the

clubs. App’x 6. Among other things, Thomas alleged, she and approximately

forty other women dancers were forced to “change clothes in an open back room,

without proper doors . . . which was monitored by video,” App’x 7; were

“pressured . . . to have sex with high-paying and recurring customers in the

champagne rooms” on the understanding that refusing to do so would result in

adverse employment action, App’x 7–8; and were pressured by managers or

“hostesses” to perform other sexual acts, App’x 7–8.

After notifying the clubs about Thomas’s charge, the EEOC formally

requested information, including the clubs’ policies regarding relationships

between customers and employees, any records of sexual harassment

complaints, and pedigree information for their employees, including each

4 employee’s name, age, sex, race, position, dates of employment, and contact

information. When the clubs objected to the request, the EEOC issued a

deficiency letter reasserting its request. The clubs again objected, asserting that

the requested information was both irrelevant and unduly burdensome to

produce.

The EEOC eventually issued two subpoenas demanding employee

pedigree information from both clubs. Reiterating their view that the pedigree

information was irrelevant and in any event too burdensome to produce, the

clubs asked the EEOC to revoke the subpoenas. The EEOC denied the request

and later petitioned the District Court to enforce the subpoenas.

The District Court granted the EEOC’s petition and issued an order

enforcing the subpoenas. The court explained that the relevance requirement “is

a low bar” and that “courts have given the term ‘relevant’ a ‘generous

construction,’ allowing access to ‘virtually any material that might cast light on

the allegations against the employer.’” App’x 67 (quoting McLane Co. v. EEOC,

581 U.S. 72, 76–77 (2017)). Because Thomas’s charge alleged widespread sexual

harassment, the District Court determined that “the employee information

would help [the EEOC] illuminate the work conditions experienced by the class

5 of female employees.” App’x 68. The District Court also concluded that the

clubs had failed to establish why complying with the subpoenas would be

difficult or disruptive to their normal business operations. See App’x 69–70.

The Respondents filed a notice of appeal and moved in the District Court

to stay the enforcement order.

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