The U.S. District Court for the Northern District of Illinois dismissed defendant Blackstone Consulting Inc. from U.S. Equal Employment Opportunity Commission v. RJB Properties Inc. et al. The district court rejected the EEOC’s efforts to expand the scope of employer liability under the “single employer” and “joint employer” theories, and granted summary judgment to Blackstone on all claims.
In this case, Blackstone was not the direct employer of any of the employees on whose behalf the EEOC alleged claims of national origin discrimination. It was included as a defendant based on the EEOC’s allegation that Blackstone was either a joint employer of the claimants at issue, or a single employer with co-defendant RJB Properties Inc., an Illinois janitorial services company that employed the claimants. Blackstone is a California company that provided consulting services, including human resource consulting, payroll, and management consulting services, to clients, including RJB Properties.
The EEOC argued that Blackstone, by providing these services, was potentially liable as a Title VII employer for the alleged acts of national origin discrimination. The court rejected the EEOC’s arguments and awarded summary judgment to Blackstone, concluding that there is no basis for liability against Blackstone, among other reasons, because it was not the employer of any of the employees at issue.