59 | EEOC-INITIATED LITIGATION: 2026 EDITION ©2026 Seyfarth Shaw LLP The company must likewise maintain detailed records of all applicants and hires and submit periodic compliance reports to the EEOC, including data on hiring practices and any complaints of discrimination or retaliation. KEY CASES FILED IN FY 2025 EEOC v. D.C. Water & Sewer Auth, Case No. 1:25 cv 03189 (D.D.C.) The EEOC brought the suit alleging age-based discrimination after the Water Authority allegedly terminated high performing and experienced older employees in the department with no history of discipline. Despite their strong performance, the EEOC contends that after their terminations, the employees were replaced by colleagues substantially younger and less qualified, indicating, to the EEOC, a pattern of age-based decision making. This was especially so, according to the EEOC, as the Water Authority failed to follow its own progressive discipline policy prior to effectuating the terminations, which would ordinarily require notice of alleged deficiencies and an opportunity to correct them. KEY SETTLEMENTS SECURED IN FY 2025 EEOC v. Equinox Holdings, Inc., Case No. 1:24 cv 03597 (D.D.C.) The EEOC filed a lawsuit alleging the employer unlawfully discriminated against a female job applicant on the bases of disability and sex. According to the EEOC’s complaint, the discriminatory conduct occurred during the employer’s hiring process for a front desk associate position. The applicant was a woman with endometriosis, a chronic aother fitness companies. Though acknowledging that her qualifications were strong, after progressing to the second round of interviews, the applicant requested that her interview be rescheduled by a few days because she was experiencing painful menstrual cramps associated with her condition. The EEOC characterized this request as a disability related request for flexibility, implicating the employer’s obligations under the ADA to consider reasonable accommodation. Rather than grant the request or otherwise engage in the interactive process, the employer rejected the applicant outright, with one interviewer stating that the applicant was passed over based on concerns of future absence due to her monthly cycle. The parties resolved the case through a two year consent decree in which the employer agreed to pay $48,000 in monetary relief. In addition to monetary relief, the employer agreed to implement and maintain anti discrimination policies consistent with the ADA and Title VII, including a procedure for applicants and employees to request reasonable accommodations. EEOC Washington, DC District Office DISTRICT PROFILE Director: Mindy Weinstein Regional Attorney: Debra Lawrence Merit Cases Filed in FY 2025: 1 Average Days Between Determination Letter & Failure to Conciliate: 53 Average Days Between Failure to Conciliate & Complaint: 70 Average Days Between Determination Letter & Complaint: 120 DC ©2026 Seyfarth Shaw LLP
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