Ninth Circuit Weighs Next Steps in Major Pay-Equity Fight
The U.S. Supreme Court vacated an earlier en banc decision after concluding the late Judge Stephen Reinhardt's vote should not have counted. Lawyers in a closely watched pay-equity case offered competing views Friday about what the en banc court should do now.
September 13, 2019 at 07:04 PM
5 minute read
Employers should not be allowed to use a job applicant's prior salary to justify paying male and female employees differently for the same work, a lawyer for a California schools professional said Friday, urging the U.S. Court of Appeals for the Ninth Circuit to adopt a ruling the court issued last year.
That earlier Ninth Circuit decision would have stopped employers from using compensation history alone or in combination with other factors to defend disparities between male and female employees. But the U.S. Supreme Court in February vacated the decision after concluding the decisive vote of a judge who died about two weeks before the ruling was issued should not have counted.
The Supreme Court did not confront the merits of the case, Rizo v. Yovino, which tests the scope of the federal Equal Pay Act. The Ninth Circuit, sitting en banc, now is weighing its next steps, and both sides in the dispute offered competing views Friday about what the appeals court should do now. The dispute has attracted widespread attention from business interests and advocates for workers.
Daniel Siegel, the attorney for Aileen Rizo, a math consultant who alleged Fresno County schools had paid her $10,000 less than male colleagues, argued Friday that the 11 judges of the Ninth Circuit en banc panel should not disturb the earlier decision favoring his client.
That divided en banc ruling, published in April 2018, was written by the late Judge Stephen Reinhardt, long considered the "liberal lion" of the Ninth Circuit. Judge Carlos Bea has been picked to replace Reinhardt on the en banc court presiding over Rizo's claims. The court has not yet said whether it will order new briefing or hold a new oral argument.
"Allowing an employer to consider prior salary along with other factors in setting an employee's initial salary might mitigate but does not eliminate the discriminatory impact of past employment practices," Siegel told the appeals court. "Even if prior salary is valued at just 10% or less in an employer's assessment of the various factors to be considered in setting a new employee's compensation, it still brings a discriminatory factor into the equation."
Siegel called Rizo's situation "a powerful rebuttal to the claim that prior salary alone can legitimately explain why a female worker is being paid less than her male colleagues." He continued: "Ms. Rizo had better qualifications and more experience than her male comparators. Nonetheless, the county started her salary at over $10,000 lower than the salary it gave them."
Lawyers for Jim Yovino, the Fresno County superintendent of schools, on Friday countered Siegel's argument that the en banc appeals court adopt the prior ruling. Yovino's attorneys at Jones Day argued in their court filing the en banc Ninth Circuit "must decide this case afresh, with a full complement of living judges."
Since the en banc Ninth Circuit issued its ruling last year in favor of Rizo, another federal appeals court, based in Richmond, Virginia, ruled employers can rely on a job candidate's prior salary history to justify a pay disparity, Jones Day partner Shay Dvoretzky said in Friday's filing.
The Fourth Circuit's decision upheld a ruling against a university professor who argued she was unlawfully being paid less than male colleagues for the same work. The appeals court determined the university had shown the salary disparity was based on a "factor other than sex." Two male colleagues were making more based on their salaries as administrators.
"Because Rizo's pay disparity stemmed from differences between her and her colleagues' prior pay, it was based on a 'factor other than sex.' As a result, the superintendent cannot be held liable under the Equal Pay Act for that disparity," Dvoretzky said.
Reinhardt had "fully participated in the original Rizo ruling before he died in March 2018, the appeals court said last year. The majority decision and concurrences were final, and the voting complete, at the time he died. Still, the Supreme Court said the Ninth Circuit was wrong to consider his vote.
"That practice effectively allowed a deceased judge to exercise the judicial power of the United States after his death," the Supreme Court said in its unsigned decision. "But federal judges are appointed for life, not for eternity."
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllUber Not Responsible for Turning Over Information on 'Dangerous Riders' to Competitor, Judge Finds
5 minute readSchools Win Again: Social Media Fails to Strike Public Nuisance Claims
5 minute readTrending Stories
- 1Why Kramer Levin Decided to Merge
- 2Judicial Ethics Opinion 24-61
- 3Decision of the Day: School District's Probe Was a 'Sham'; Title IX Administrator Showed Sex-Based Bias
- 4US Magistrate Judge Embry Kidd Confirmed to 11th Circuit
- 5Shaq Signs $11 Million Settlement to Resolve Astrals Investor Claims
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250