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Dollar Tree Hires Former EEOC Chair Dhillon as New Top Lawyer

Nov. 23, 2022, 7:59 PM

Dollar Tree Inc. hired Janet Dhillon as its chief legal officer, weeks after she stepped down as a Republican member of the Equal Employment Opportunity Commission.

Dhillon confirmed via email she started Monday at Dollar Tree. She has previously been legal chief for Burlington Stores Inc., J.C. Penney Corp., and US Airways Inc.

Her hire follows a summer shakeup of executives at the Chesapeake, Va.-based discount variety chain. Dollar Tree made waves last year for raising the baseline price for items in its stores from $1 to $1.25.

The company has paid hundreds of thousands of dollars in fines within the past decade over allegations that it repeatedly violated federal workplace safety rules.

Dhillon, who was previously EEOC chair, continued to serve on the commission after her term expired in July. The Biden administration’s pick for her replacement—civil rights lawyer Kalpana Kotagal—has yet to be confirmed by the Senate.

Dhillon’s tenure saw the EEOC propose a policy change to slow the process for filing bias suits against employers, as well as limit the ability of workplace civil rights agencies to access employer diversity data.

Executive Overhaul

Dhillon succeeds Dollar Tree’s longtime former legal chief, William Old Jr., who parted ways with the company over the summer. Old departed as Dollar Tree shook up its entire C-suite, installing a new chief executive and several other executives.

The company has yet to disclose Dhillon’s pay package.

Her appointment to the EEOC in 2017 was welcomed by top in-house lawyers for many retailers, who were keen on having an ally on the commission during the Trump administration.

Dhillon spent the first 13 years of her career at Skadden, Arps, Slate, Meagher & Flom in Los Angeles and Washington.

A government disclosure form filed at the time of Dhillon’s move to the EEOC five years ago showed that she left behind a $1.5 million annual salary at Burlington Stores to take up public service.

She previously spent a half-dozen years as legal chief for retailer J.C. Penney. Dhillon received more than $2.7 million in total compensation in 2012 as the company sparred with activist investor William Ackman.

Prior to that Dhillon spent five years at US Airways, including three as the airline’s chief legal and compliance officer. Those roles saw her handle the fallout from the “Miracle on the Hudson,” a crash landing by pilot Chesley “Sully” Sullenberger.

At Dollar Tree, Dhillon will be the company’s top lawyer and corporate secretary, she said. The company earlier this month added a new chief compliance officer, Jennifer Bohaty, who most recently held a similar role at LL Flooring Holdings Inc., a Richmond, Va.-based retailer formerly known as Lumber Liquidators.

In August, Davis Polk & Wardwell white-collar litigation and investigations counsel Gabriel Jaime-Bettan was seconded to Dollar Tree as special counsel and acting compliance chief. Edward Kelly III, a former Davis Polk partner and retired chairman of Citigroup Inc.’s institutional businesses, is a member of Dollar Tree’s board.

Jaime-Bettan and Bohaty, as part of Dollar Tree’s compliance function, both report to Dhillon, she said. News of Dhillon’s new job was first reported by Law360.

Dhillon is married to Uttam Dhillon, a former White House lawyer in the Trump administration. He joined Michael Best & Friedrich last year as chair of the law firm’s regulatory defense, compliance, and white-collar practice group.

To contact the reporter on this story: Brian Baxter in New York at

To contact the editors responsible for this story: Chris Opfer at; John Hughes at