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Duane Morris Takeaways: On September 12, 2025, in EEOC v. Support Center for Child Advocates, No. 2:25-CV-00310, (E.D. Pa. Sept. 12, 2025), Judge John F. Murray of the U.S. District Court for the Eastern District of Pennsylvania denied the EEOC's second unopposed motion for approval of a consent decree between the EEOC and Support Center for Child Advocates. The Court remained unsatisfied with the lack of information with which the Court could assess the appropriateness of the parties' agreement.
This ruling demonstrates that approval of an agreed upon consent decree is anything but a guaranteed rubber stamp. Instead, it shows the importance of providing a factual basis and thorough reasoning to justify gaining court approval, even when motions are unopposed.
Case Background
On January 17, 2025, the EEOC, on behalf of charging party Meghan Seitz, filed a lawsuit against Defendant Support Center for Child Advocates regarding allegations of pregnancy discrimination under Title VII of the Civil Rights Act of 1964. (ECF 1.) Specifically, the EEOC alleged that the child advocacy organization discriminated against Ms. Seitz, a former employee with a high-risk pregnancy, when the organization denied Ms. Seitz an accommodation to work remotely during the COVID-19 pandemic. (Id. ¶¶ 21–24.)
On August 15, 2025, the EEOC first moved for approval of the proposed consent decree. (ECF 29.) The motion includes the consent decree as "Exhibit A," which sets forth the parties' agreed-upon plan for Support Center for Child Advocates to provide future accommodations to similar employees, adopt an Equal Employment and non-discrimination policy, implement human resources and management personnel training, inform workers about their rights to accommodations, and pay Seitz $30,000, among other provisions. (ECF 29-1.)
The Court denied the EEOC's initial motion for entry of the consent decree on August 18, 2025. (ECF 30.) The Court reasoned that the motion requested the consent decree be entered "for the reasons stated therein" but included no reasons stated therein. (Id. at 1 n.1.)
The Court opined that it had no way of knowing whether the agreement was appropriate or not. As a solution, the Court invited the parties to either file a stipulated dismissal after agreeing amongst themselves to the terms of the proposed consent decree or refile the motion with additional information.
Most Recent Filings And Order
On September 8, 2025, the EEOC filed a supplemental motion for entry of the consent decree, which provided an overview of the procedural history of the case. (ECF 31.) The EEOC also filed an unopposed memorandum in support of its motion. (ECF 31-1.) In the memorandum, the EEOC further outlined the case history, labeled as the statement of the case, and argued that settlement through a consent decree is a regular and appropriate manner of resolution and that the proposed consent decree satisfies the legal standard for judicial review.
On September 12, 2025, the Court denied the EEOC's second motion for entry of the consent decree, finding the motion did not provide an adequate factual basis from which the Court could assess the appropriateness of the consent order. (ECF 32.) To resolve this issue, the Court noted that it would be willing to conduct an evidentiary hearing to build a record if the parties were interested. (Id. at 1 n.1.)
Implications For Employers
The Court's denial of the second motion for entry of the proposed consent decree in EEOC v. Support Center for Child Advocates should serve as a cautionary reminder to litigants that courts will not merely rubber-stamp EEOC consent decrees where a sufficient factual basis justifying approval is not provided to courts.
Litigants must provide courts with more information than mere conclusory statements that the proposed consent decree is fair and reasonable for courts to approve of consent decrees. Otherwise, litigants may find themselves forced to backtrack in the settlement approval process.
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