| Merit System No Defense in Equal Pay Act Suit if System Not Implemented | |
| Description | Appeals court upheld verdict for woman engineer who sued her former employer for violating the Equal Pay Act. She was able to show that while a merit system was in place for determining pay increases, it was not applied in practice, so the merit system defense did not apply. |
| Topic | Employment Discrimination |
| Key Words | Equal Pay Act; Merit Systems |
| C A S E S U M M A R Y | |
| Facts | Ryduchowski sued her former employer, the Port Authority, for violation of the Equal Pay Act. She is a civil engineer who worked for the Authority for seven years before being fired. Pay increases were tied to annual evaluations. She contended that her evaluations were lower than they should have been due to sexual discrimination, so she was paid less than her peers. The Port Authority defended that it followed merit system rules in promotion and raises. The jury found in her favor; the Port Authority appealed. |
| Decision | Affirmed. Ryduchowski provided a prima facie case of discrimination, as male employees with the same ability and ranking were given higher pay. "The Port Authority failed, contrary to its written policy, to take into account employees' attendance records and positions within salary grade in determining merit increases. Although the lone document submitted at trial as to the administration of the Port Authority's merit system stated that these factors would be considered, there was no evidence that these factors were actually considered." The jury could, therefore, conclude that the Port Authority failed to correlate merit increases to evaluations. |
| Citation | Ryduchowski v. Port Authority of New York and New Jersey, 203 F.3d 135 (2nd Cir., 2000) |
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