EEOC Filed 110 Discrimination Lawsuits for Fiscal Year 2024

January 06, 2025

As 2025 begins, we highlight the U.S. Equal Employment Opportunity Commission (EEOC)’s litigation focus in fiscal year 2024. Despite the upcoming change in presidential administrations, we do not anticipate immediate changes within the EEOC. The EEOC Commission members are presidential appointees serving five-year staggered terms. There is currently one vacancy, and the first expiration of a term will be in July 2025.

During fiscal year 2024, the EEOC filed 110 employment discrimination lawsuits. These lawsuits demonstrated a trend of what the EEOC characterizes as an effort to protect vulnerable employees, address emerging issues, and challenge systemic harassment, all in accordance with the EEOC’s Strategic Enforcement Plan (SEP) released for fiscal years 2024 to 2028.

Chicago, Ill. (January 6, 2025) - As 2025 begins, we highlight the U.S. Equal Employment Opportunity Commission (EEOC)’s litigation focus in fiscal year 2024. Despite the upcoming change in presidential administrations, we do not anticipate immediate changes within the EEOC. The EEOC Commission members are presidential appointees serving five-year staggered terms. There is currently one vacancy, and the first expiration of a term will be in July 2025.

During fiscal year 2024, the EEOC filed 110 employment discrimination lawsuits. These lawsuits demonstrated a trend of what the EEOC characterizes as an effort to protect vulnerable employees, address emerging issues, and challenge systemic harassment, all in accordance with the EEOC’s Strategic Enforcement Plan (SEP) released for fiscal years 2024 to 2028.

The 110 lawsuits include claims brought under the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), the Pregnant Workers Fairness Act (PWFA), Title VII of the Civil Rights Act of 1964 (Title VII), and various statutes enforced by the EEOC involving retaliation. In addition, the EEOC filed 13 new systemic cases alleging a pattern, practice, or policy of discrimination in the workplace. Systemic litigation initiated by the EEOC has increased over recent years, and systemic cases comprised 22% of the EEOC’s docket at the end of fiscal year 2024.

Nearly half of the EEOC’s 110 cases were brought under the ADA. These cases largely challenged employer classification standards and policies. For instance, many of these cases addressed policies regarding factors for assessing absences related to an employee’s disability or policies requiring employees to work without medical restrictions and no consideration of accommodations.

Notably, the EEOC also filed five lawsuits focused on the enforcement of the PWFA, which took effect on June 27, 2023. The PWFA requires employers to provide a reasonable accommodation, absent undue hardship, to qualified employees’ known limitations arising from pregnancy, childbirth, lactation, or a related medical condition. These lawsuits allege that employers failed to provide reasonable accommodations to eligible employees pursuant to the PWFA, and in most cases discharged such employees as a result.

In addition to the 110 lawsuits discussed above, the EEOC filed 18 lawsuits for failure to submit EEO-1 Component 1 annual data reports in compliance with mandatory federal reporting requirements, as well as one lawsuit asserting breach of a conciliation agreement.

If you have any questions about these developments, contact the author of this alert. Visit our Labor & Employment Practice page to learn more about our capabilities in this area.