EEOC Reclaims Litigation Authority After Decades Of Harmful Delegation

January 28, 2026

 

What's New

The EEOC has voted to reclaim litigation authority that it improperly delegated to its General Counsel three decades ago. Under Title VII and other civil rights laws, the Commission itself is authorized to bring civil actions against private sector employers when discrimination claims can’t be resolved through conciliation.

In the 1990s, the Commission delegated nearly all of this authority to the General Counsel and allowed further re-delegation to regional offices, purportedly for efficiency. In practice, that decision weakened accountability and contributed to lawsuits built on questionable legal theories and inconsistent enforcement positions.

Last week, by a 2-1 vote, the Commission ended this delegation. Under the new procedure, the Commission now will vote on whether to commence or intervene in litigation in nearly all cases, with narrow exceptions for recordkeeping matters and enforcement of settlement agreements.

What It Means

This is a positive and long-overdue course correction. By reclaiming responsibility for litigation decisions, the EEOC is restoring meaningful oversight to one of its most consequential enforcement functions. Greater Commission involvement should lead to more disciplined decision-making, greater consistency, and litigation positions that more accurately reflect governing law.

For private sector employers, this change has the potential to reduce exposure to poorly vetted lawsuits and promote a more credible, accountable enforcement program.

What You Should Do

Register for CWC’s 2026 Workplace Policy Conference where we’ll discuss the practical implications of this change and what it signals about the EEOC’s broader enforcement priorities.





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