Frozen Pipeline: Examining the EEOC’s Quietest Year in a Decade
Seyfarth Synopsis: While we viewed the EEOC’s Fiscal Year 2024 as “ sluggish ,” the Commission entered FY 2025 with a hefty budget, a brimming pipeline of charges, and a Democratic majority of Commissioners, suggesting a robust year of EEOC-initiated litigation was on the way. The EEOC’s fiscal year closed today , and what promised to be an watershed year was anything but. The Trump Administration’s swiftly implemented leadership changes, budget cuts, and dramatic shift in priorities led to a roller-coaster for field staff and employers alike. Ultimately, the EEOC filed just 93 lawsuits in FY 2025, marking a ten-year low in Commission litigation activity. Despite a notable pullback in litigation activity, a close analysis of FY 2025 filings can help employers identify the EEOC’s priority areas and understand what to expect going forward. In previous administrations, the EEOC’s litigation arm was extraordinarily active, filing as many as 300 merit lawsuits in a given year. T...