©2026 Seyfarth Shaw LLP EEOC-INITIATED LITIGATION: 2026 EDITION | 52 accommodation related to her medical condition. As alleged by the EEOC, instead of engaging in the required interactive process to discuss and implement accommodations, the employer terminated her employment. KEY SETTLEMENTS SECURED IN FY 2025 EEOC v. Elon Prop. Mgmt. Co., LLC, Case No. 8:24-CV-02939-MSS-LSG (M.D. Fla.) The EEOC reached a settlement with a residential property management company following allegations of disability discrimination and retaliation in violation of the Americans with Disabilities Act. The EEOC alleged that the employer retaliated against a district manager who had taken a medical leave of absence by placing her on a performance improvement plan immediately upon her return and penalizing her for a decline in occupancy rates that occurred while she was on leave. Additionally, the EEOC charged that the employer maintained policies that screened out employees with disabilities by requiring a full-duty release note and a physician-signed copy of the employee’s job description before allowing a return from medical leave. These practices effectively barred employees who needed accommodations from returning to work, which the EEOC stated was unlawful under the ADA. The case resolved through a three-year consent decree under which the employer agreed to pay $200,000 in monetary relief to multiple former employees. The employer also agreed to revise and redistribute its ADA and leave policies, provide specialized ADA training to all employees, and post notices informing employees of their rights under the ADA. EEOC v. Enterprise Leasing Co. of Florida, LLC, Case No. 0:23-61744 (S.D. Fla.) The EEOC reached settlement following allegations of systemic age discrimination in violation of the Age Discrimination in Employment Act. The EEOC alleged that, beginning in at least 2019, the employer consistently refused to hire applicants aged 40 and older for its management trainee positions. Although roughly 15% of applicants for these roles were in the protected age group, they accounted for less than 3% of hires. Pre the EEOC, its investigation revealed that more than 125 witnesses reported being asked their age or graduation year during interviews, told that most candidates were “fresh out of college,” or otherwise discouraged from applying based on age. The matter was resolved through a three-year consent decree under which the employer agreed to pay $1.8 million in monetary relief to affected applicants and ensure ADEA compliance, providing annual age discrimination training to all relevant personnel, posting notices about employees’ rights under the ADEA, and conducting mandatory investigations of all age discrimination complaints. Additionally, the employer must establish bi-annual reporting requirements, implement an applicant tracking system to monitor hiring practices, and maintain a publicly accessible Ethics Hotline for reporting discrimination concerns.
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