Employment Litigation · Primary-source case analysis

CRST: A Title VII Defendant Can Prevail Without a Merits Ruling

By Aneeta Mishra and Timothy Chan

Published September 6, 2026

CRST Van Expedited, Inc. v. EEOC followed an EEOC harassment action in which numerous claims were dismissed after the district court found failures in investigation or conciliation and other defects.

The EEOC identified many claimants during discovery

The agency sued after investigating a charge by one driver and later identified more than 250 allegedly aggrieved women.

The district court dismissed the claims and awarded fees

Among other rulings, the court dismissed claims because the agency had not adequately investigated or attempted conciliation and awarded CRST more than four million dollars.

A merits ruling was not categorically necessary

A defendant seeks to prevent the plaintiff from altering the parties’ legal relationship. A final rejection can accomplish that objective for a nonmerits reason.

The Court left fee-specific questions open

The Court vacated and remanded without deciding preclusion or whether the EEOC position was frivolous, unreasonable, or groundless under the governing fee standard.

Key takeaways

• Identify the precise judgment and claims on which defendant prevailed.
• Separate prevailing-party status from the stricter fee-award standard.
• Preserve the investigation, conciliation, and dispositive-motion record.
• Do not assume every procedural dismissal supports fees.