## Facts

- Carrols Corporation operated more than 500 Burger King franchise restaurants in the United States.
- A Carrols employee filed a charge with the Equal Employment Opportunity Commission (EEOC) alleging that female employees faced sexual harassment and that those who complained were retaliated against.
- After investigating, the EEOC concluded Carrols had tolerated an environment of sexual harassment and had engaged in a pattern of sex-based discrimination in violation of Title VII of the Civil Rights Act of 1964.
- The EEOC filed suit on November 17, 1998 in the U.S. District Court for the Northern District of New York, alleging sexual harassment, retaliation, and constructive discharge affecting multiple female employees, including the charging party and others.
- The case was long-running and included litigation activity before the parties ultimately reached a negotiated resolution.
- Following extensive settlement negotiations, the EEOC and Carrols jointly submitted a proposed consent decree for court entry as the final disposition.
- The proposed decree contemplated monetary relief for identified claimants (described publicly as 89 women) and extensive injunctive and compliance obligations, including training, written policies, audits, and a reporting hotline.
- The parties agreed the decree could be entered without findings of fact or conclusions of law, and Carrols denied the complaint’s allegations and any unlawful conduct.

## Issues

1. Whether the court should approve and enter the parties’ proposed consent decree resolving the EEOC’s Title VII claims alleging sexual harassment and retaliation by Carrols.
2. What monetary and forward-looking terms the decree should impose to remedy the alleged Title VII violations and reduce the risk of future harassment and retaliation during the decree term.

## Decision

- The court entered the consent decree in *Equal Emp’t Opportunity Comm’n v. Carrols Corp.*, No. 98‑CV‑1772 (FJS)(TWD) (N.D.N.Y. Jan. 10, 2013) (Consent Decree), and the matter was resolved subject to the decree’s enforcement provisions.
- Carrols agreed to pay a total of $2,500,000 into a claim fund for designated claimants, covering payments characterized as back pay and compensatory damages.
- The decree set out tax-treatment mechanics for payments (including W‑2 reporting for back pay and 1099 reporting for compensatory damages) and required uncashed checks after a set period to be paid to a mutually agreed § 501(c)(3) organization aligned with Title VII’s anti-harassment goals.
- Carrols and its management were enjoined from sexual harassment of female employees and from retaliation against individuals who complained of harassment, opposed discrimination, filed charges, or participated in Title VII proceedings.
- Carrols was required to maintain and use written anti-discrimination and anti-harassment policies and to provide training addressing sexual harassment, retaliation, and reporting duties, including training for new hires and additional training for managers and supervisors.
- The decree required complaint-reporting avenues, including a hotline, and set expectations for handling and tracking complaints.
- Carrols was required to conduct audits of relevant human-resources practices and to provide information to the EEOC during the decree term as specified by the decree.
- Carrols was required to post court-approved notices and EEOC materials at covered restaurant locations, including locations existing as of a specified date and additional locations acquired later.
- The court retained jurisdiction to enforce the decree, and the decree included a notice-and-cure process before the EEOC could seek judicial enforcement for an alleged breach.

## Legal Principles

- A consent decree is a settlement entered as a court order; it is binding and enforceable even though it does not reflect a trial judgment on liability.
- Title VII prohibits sex discrimination, including sexual harassment that creates a hostile work environment, and prohibits retaliation against individuals who complain about discrimination or participate in enforcement processes.
- In Title VII enforcement actions, negotiated injunctive relief may include policy requirements, training obligations, complaint channels, recordkeeping, audits, notice posting, and ongoing reporting, designed to prevent harassment and retaliation during a court-supervised term.
- A federal district court may retain jurisdiction to enforce a consent decree and may require pre-enforcement dispute-resolution steps (such as notice and an opportunity to cure) as part of the decree’s structure.

## Conclusion

In *EEOC v. Carrols Corp., Consent Decree (2013)*, the Northern District of New York entered a negotiated Title VII consent decree resolving the EEOC’s long-running sexual-harassment and retaliation lawsuit without liability findings, requiring Carrols to pay $2.5 million to designated claimants and to carry out detailed workplace measures—injunctions against harassment and retaliation, training, written policies, complaint reporting (including a hotline), audits, notice posting, and court-enforceable reporting and compliance procedures.
