The U.S. Equal Employment Opportunity Commission

Office of General Counsel

Annual Report
Fiscal Year 2002



Table of Contents

  1. Structure and Function of the Office of General Counsel
    1. Mission of the Office
    2. Headquarters Programs
    3. District Office Legal Units
  2. Summary of Accomplishments
    1. Overview of Fiscal Year 2002
    2. Litigation Highlights
  3. Statistical Analysis of EEOC Litigation
    1. Generally
    2. Suits Filed
    3. Suits Resolved
    4. Resources
  4. Significant Appellate Decisions and Briefs
    1. Appellate Highlights
    2. Significant Decisions
    3. Significant Appellate Briefs

I. STRUCTURE AND FUNCTION OF THE OFFICE OF GENERAL COUNSEL

A. Mission of the Office

The General Counsel conducts litigation on behalf of the Commission under four federal statutes, seeking relief for victims of the basis of race, color, religion, gender, national origin, age and disability.

In 1964 Congress passed the Civil Rights Act, which prohibits discrimination on the basis of race, color, religion, sex and national origin. The Civil Rights Act of 1964 created the U.S. Equal Employment Opportunity Commission to oversee the employment provisions prohibiting discrimination, which were embedded in Title VII of the Act. The Commission, however, had no ability to enforce these provisions until Congress amended Title VII in 1972 and authorized the EEOC to file suit in federal court. At the same time, Congress created the position of General Counsel, responsible for conducting the Commission's litigation. The General Counsel is appointed by the president and confirmed by the Senate for a four year term.

As the EEOC's statutory duties have grown, so has the litigation responsibility of the General Counsel. In 1979, a Presidential Order transferred the enforcement functions for the Age Discrimination in Employment Act (ADEA) and the Equal Pay Act (EPA) from the Department of Labor to the EEOC. In 1990, Congress enacted the Americans with Disabilities Act (ADA), vesting authority for the enforcement of the employment provisions with the EEOC.

Title VII and the ADA cover employers with 15 or more employees; the ADEA covers employers with 20 or more employees; and the EPA covers all private employers. Although the Department of Justice brings suits against state and local governments under Title VII and the ADA, the Commission files suits against state and local governments under the ADEA and the EPA.

B. Headquarters Programs

C. District Office Legal Units

Located throughout the country, the EEOC's District Office Legal Units help investigate discrimination charges and litigate cases filed in court.

The Commission currently has 24 District Offices, each, except for Albuquerque, containing a legal unit which conducts Commission litigation. The legal units also provide advice and other legal support to the District Office enforcement units, which are responsible for investigating charges of discrimination. Thus, in addition to litigating cases, legal unit attorneys work closely with the enforcement units in the intake and investigation of charges and responding to Freedom of Information Act requests.

Each District Office legal unit is under the direction of a Regional Attorney. The Regional Attorneys manage staffs of one to two supervisory trial attorneys and five to fifteen trial attorneys, as well as support staff. Since 1999, the Regional Attorneys also manage trial attorneys stationed in approximately twenty-one local and area offices as well as in the Washington Field Office. Additionally, many Regional Attorneys supervise a Hearings Unit, composed of administrative judges who conduct hearings on claims of discrimination in federal employment.

II. SUMMARY OF ACCOMPLISHMENTS

A. Overview of Fiscal Year 2002

B. Litigation Highlights

III. STATISTICAL ANALYSIS OF EEOC LITIGATION

A. Generally

On October 1, 2001, the start of fiscal year 2002, there were 523 merit cases in active litigation. (Direct suits, interventions and suits to enforce conciliation agreement are "merit" suits.) In FY 2002, OGC filed 332 merit suits for a total litigation workload of 855. OGC also resolved 345 merit cases throughout this year. At the end of the fiscal year (September 30, 2002), there were 510 cases in active litigation. The 345 merit resolutions yielded a total of $52,845,499 in monetary relief.

B. Suits Filed

In FY 2002, the field legal units filed 332 merit lawsuits; 327 direct suits and interventions and five suits to enforce conciliation agreements. 4

Merit Filings in FY 2002
  Count Percent
Direct 326 98.2%
Intervention 1 0.3%
Administ. Enf 5 1.5%
Total 332 100.0%

C. Suits Resolved

In FY 2002, the Office of General Counsel resolved a total of 345 merit lawsuits (direct suits, interventions and suits to enforce administrative settlements). 5 These 345 resolutions yielded a total of $52,845,499 in relief.

Merit Resolutions in FY 2002
  Count Percent
Direct 340 98.5%
Intervention 2 0.6%
Administ. Enf. 3 0.9%
Total 345 100.0%

As shown in the table below, the number of merit resolutions was up in FY 2002 compared with FY 2001. Similarly, the total monetary relief was up by $1.6 million.

Resolutions in FYs 2001 and 2002
  FY 2001 FY 2002 Change
Merit Suits 319 345 + 8.2%
Relief (in millions) $51.2 $52.8 + 3.1%

The number of merit resolutions in FY 2002 was greater than the average of the last five fiscal years (see table below).

Resolutions Since FY 1997
  Average
FYs 1997-2001
FY 2002
Merit Suits 310.4 345

D. Resources

EEOC Litigation: 1993 - 2002

FY 93 FY 94 FY 95 FY 96 FY 97 FY 98 FY 99 FY 00 FY01 FY02
ALL SUITS FILED 481 425 373 193 330 411 464 328