Employer Subject To Limited Injunction To “Obey the Law”

By Mike Grubbs

In EEOC v. AutoZone, Inc., No. 07-CV-1154 (7th Cir. Feb. 15, 2013), the EEOC got the court to affirm an injunction against an employer to “obey the law.” In the case, a jury found the employer violated the Americans with Disabilities Act (ADA) by failing to accommodate an employee’s disability. (The direct supervisors had accommodated the employee by relieving him from cleaning duties, but their district manager overruled the supervisors.) The employee got compensatory damages, back pay and punitive damages. The EEOC got an injunction requiring the employer, among other things, to comply with the ADA accommodations requirement in the Central District of Illinois.

On appeal, the 7th Circuit U.S. Court of Appeals decided the “obey the law” injunction was appropriate under the circumstances, and it was appropriately limited to a specific region. However, the court of appeals sent the case back to the district court to impose a reasonable time limit. Otherwise, any future local violation by the employer of the ADA requirement could be enforced by direct application to the court for a contempt citation, by-passing the EEOC’s usual obligations to investigate, reach a determination, conciliate and sue.

An “obey-the-law” injunction is rare, but the court okayed it here because the employer hadn’t fixed its policies or practices despite 8 years of litigation with the EEOC. Practical takeaway from this case—you can avoid “obey the law” injunctions by obeying the law.

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