©2026 Seyfarth Shaw LLP EEOC-INITIATED LITIGATION: 2026 EDITION | 28 • EEOC v. Mercyhealth, Case No. 3:24-cv-50345 (N.D. Ill.):64 On July 31, 2025, the EEOC announced that Mercyhealth agreed to pay $1,000,000 and provide injunctive relief to settle a lawsuit alleging religious discrimination under Title VII of the Civil Rights Act of 1964. The EEOC claimed that Mercyhealth failed to accommodate employees’ religious objections to its COVID-19 vaccine mandate and terminated those who refused vaccination based on sincerely held beliefs. According to the EEOC, Mercyhealth did not engage in an interactive process and instead enforced a blanket policy denying exemptions. The consent decree requires Mercyhealth to revise its accommodation procedures, train managers and HR staff on Title VII compliance, and submit biannual reports to the EEOC for three years. • EEOC v. Mayo Clinic, Case No. 0:25-cv-01987 (D. Minn.):65 On October 8, 2025, the EEOC filed a lawsuit alleging that Mayo Clinic violated Title VII of the Civil Rights Act of 1964 by failing to accommodate employees’ religious objections to its COVID-19 vaccine mandate and terminating those who refused vaccination based on sincerely held beliefs. According to the EEOC, Mayo Clinic enforced a blanket policy denying religious exemptions and did not engage in an interactive process with affected employees. The suit seeks monetary damages and injunctive relief, including policy changes and training to ensure compliance with Title VII’s accommodation requirements. E. EEOC Focus on Equal Pay Protections The EEOC is the federal government’s most powerful agency for the enforcement of federal anti-discrimination laws in the workplace. Authorized by Congress to wield broad investigative and subpoena powers for the prevention and remediation of unlawful employment practices, the EEOC’s enforcement mechanisms cover a range of activities, from individual and systemic claims investigations, conciliation, litigation and monitoring compliance, to serving as an agent for effecting broader policy change in employment sectors throughout the country. Each iteration of the EEOC’s Strategic Enforcement Plan has included a focus on advancing equal pay for all workers.66 The number of EEOC lawsuits alleging equal pay violations has dropped significantly in recent years. This has led to a decline in legal decisions relating to equal pay issues, at least those involving the EEOC as a party. Indeed, the EEOC filed only two Equal Pay Act (“EPA”) cases in federal court in 2024, and zero such cases in 2025. While the recent Trump EEOC has not focused on EPA claims thus far, it has sought to enforce pay discrimination claims under Title VII. For example, in EEOC v. Seward and Son Planting Company, 4:25-cv155, the EEOC alleged that the defendant violated Title VII by subjecting a class of employees to disparate treatment in their pay and terms and conditions of employment on the basis of their race (black) and national origin (United States of America). On November 25, 2025, the EEOC announced that Seward and Son would pay $150,000 and implement policy changes by way of a three-year consent decree to settle those claims.67 In another recent matter, EEOC v. TKO Construction Services, No. 23-cv-3010 JRT TNL, the defendant agreed to pay $300,000 to settle race and sex discrimination claims under Title VII, including claims that female and black employees received less pay than male and white employees.68 64 https://www.eeoc.gov/newsroom/mercyhealth-pay-over-1-million-settle-eeoc-covid-19-vaccine-mandate-related-religious 65 https://www.eeoc.gov/newsroom/eeoc-sues-mayo-clinic-religious-discrimination 66 See U.S. Equal Employment Opportunity Commission Strategic Enforcement Plan FY 2024-2028, Strategic Enforcement Plan Fiscal Years 20242028 | U.S. Equal Employment Opportunity Commission (eeoc.gov). 67 See https://www.eeoc.gov/newsroom/seward-and-son-pay-150000-eeoc-race-and-national-origin-discrimination-lawsuit 68 See https://www.eeoc.gov/newsroom/tko-construction-services-pay-300000-settle-eeoc-sex-race-and-age-discrimination-lawsuit
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