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E.E.O.C. v. Hp Pelzer Automotive Systems, Inc.
Citation: 363 F. Supp. 3d 864Docket: No.: 1:17-CV-31-TAV-CHS
Court: District Court, E.D. Tennessee; March 11, 2019; Federal District Court
Plaintiffs' motion in limine to exclude testimony regarding the Equal Employment Opportunity Commission's (EEOC) administrative findings has been granted by the Court. Intervening plaintiff Estela Black filed an EEOC charge on June 19, 2015, alleging sexual harassment and retaliation. The EEOC found reasonable cause to believe she was terminated in retaliation but did not find reasonable cause for the sexual harassment claim. Plaintiffs contended that the EEOC’s findings were irrelevant and argued that their probative value was significantly outweighed by the potential for unfair prejudice and jury confusion. The Court considered arguments from both parties, noting the low probative value of EEOC determinations and the potential for significant prejudice, as highlighted in prior case law. The defendant argued that the EEOC findings were relevant due to the plaintiffs' claim that the defendant's investigation was flawed. However, the Court determined that the jury could assess the reasonableness of the defendant's investigation independently. The findings of the EEOC and defendant were based on different standards, and introducing these findings could mislead the jury regarding the nature of the investigations. Ultimately, the Court concluded that any probative value of the EEOC's findings was substantially outweighed by the risks of unfair prejudice and confusion, leading to the decision to grant the plaintiffs' motion to exclude the EEOC's administrative findings from trial.