West Case Update

Job Titles Matter Less Than Substance of Job Duties When Comparing Pay Differentials

Description Appeals court upheld the dismissal of a suit brought for violation of equal pay for equal work. While the male and female employees had the same job titles, the female employee had no managerial duties, so the substance of their jobs was different, which is the focus of inquiry in such cases.

Topic Employment Discrimination

Key Words Equal Pay Act; Sex Discrimination; Prima Facie Case

C A S E S U M M A R Y

Facts Rodriguez started working at Smithkline in 1979. She was promoted several times, but she was never in a managerial position. She sued for violation of the Equal Pay Act and Title VII, contending that in one position she was paid less than a male employee of similar responsibility. The district court dismissed her suit, holding that she had failed to make out a prima facie case of discrimination and, further, that she had not shown Smithkline's proffered reasons to be pretextual. She appealed.

Decision Affirmed. The employer showed that the pay difference was due in part to job restructuring and reassignments and due to the fact that the male employee had his salary and grade level protected during the reorganization of the company. Furthermore, while the two had the same job title, the male employee had managerial duties that Rodriguez did not. The substance of jobs, not their title, is most important. Hence, Rodriguez failed to make a prima facie showing that she was paid less than a male employee was for substantially equal work.

Citation Rodriguez v. Smithkline Beecham, 224 F.3d 1 (1st Cir., 2000)

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Job Titles Matter Less Than Substance of Job Duties When Comparing Pay Differentials
Description	Appeals court upheld the dismissal of a suit brought for violation of equal pay for equal work. While the male and female employees had the same job titles, the female employee had no managerial duties, so the substance of their jobs was different, which is the focus of inquiry in such cases.
Topic	Employment Discrimination
Key Words	Equal Pay Act; Sex Discrimination; Prima Facie Case
C A S E S U M M A R Y
Facts	Rodriguez started working at Smithkline in 1979. She was promoted several times, but she was never in a managerial position. She sued for violation of the Equal Pay Act and Title VII, contending that in one position she was paid less than a male employee of similar responsibility. The district court dismissed her suit, holding that she had failed to make out a prima facie case of discrimination and, further, that she had not shown Smithkline's proffered reasons to be pretextual. She appealed.
Decision	Affirmed. The employer showed that the pay difference was due in part to job restructuring and reassignments and due to the fact that the male employee had his salary and grade level protected during the reorganization of the company. Furthermore, while the two had the same job title, the male employee had managerial duties that Rodriguez did not. The substance of jobs, not their title, is most important. Hence, Rodriguez failed to make a prima facie showing that she was paid less than a male employee was for substantially equal work.
Citation	Rodriguez v. Smithkline Beecham, 224 F.3d 1 (1st Cir., 2000)