Second Circuit: Equal Pay Claims are Easier to Reach for Employees


All Employers with CT, NY, and VT Employees


December 6, 2019


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In Lenzi v. Systemax, Inc., the Second Circuit Court of Appeal addressed a gender discrimination claim under Title VII based on unequal pay. There, the court stated that a female employee, claiming she was paid less than the men who also held Vice President titles within the company, only needed to show that she was discriminated against based on her sex. She did not need to show that she was paid less than her male peers or that they held substantially equal positions to hers.

Essentially, the court distinguished the standards of proof required between unequal pay claims brought under Title VII of the Civil Rights Act of 1964 versus under the Equal Pay Act of 1963, making the bar for equal pay claims lower under Title VII. Employers should expect to see more Title VII claims for allegations of unequal pay based on sex discrimination.

Action Items

  1. Have a compensation audit conducted to review equal pay.
  2. Have applicable managers trained on setting pay rates.
  3. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser.

© 2020 ManagEase

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