County of Washington v. Gunther
Headline: Title VII wage claims expanded as Court affirms that workers may sue for intentional sex‑based pay discrimination even when jobs are not 'equal,' opening Title VII relief beyond Equal Pay Act equal‑work only cases.
Holding: The Court held that Title VII permits sex‑based wage discrimination suits even when the jobs are not equal under the Equal Pay Act, allowing workers to prove intentional underpayment because of sex.
- Allows workers to sue under Title VII for intentional pay discrimination even if jobs are unequal.
- Gives employees not covered by the Equal Pay Act a Title VII remedy for intentional pay bias.
- Sends cases back for factfinding on whether pay differences were intentionally based on sex.
Summary
Background
A county in Oregon paid women who guarded female prisoners substantially less than men who guarded male prisoners. Four women who worked as female jail guards sued under Title VII seeking back pay. They alleged either that they performed substantially equal work or that the county intentionally set the female pay scale below market and the value of the jobs. The district court found the jobs unequal and dismissed the intentional‑discrimination claim as barred by the Equal Pay Act's "equal work" test; the Ninth Circuit reversed and allowed proof on intentional discrimination.
Reasoning
The Court considered whether the Bennett Amendment limits Title VII sex‑based pay claims to matters that meet the Equal Pay Act's equal‑work requirement. Reading the amendment and its history, the Court concluded it incorporated the Equal Pay Act's four listed defenses (seniority, merit, production, and other non‑sex factors) but did not automatically bar Title VII suits where jobs are not equal. The Court therefore held workers may bring Title VII claims to prove intentional pay discrimination even if they cannot meet the Equal Pay Act's equal‑work standard. The Court emphasized its holding is narrow and does not approve broad 'comparable worth' claims.
Real world impact
Workers in unique or predominantly female jobs can pursue Title VII claims to prove intentional underpayment because of sex, and employees not covered by the Equal Pay Act retain a Title VII avenue. The case returns to the district court for factfinding on intentional discrimination. This decision does not require courts to order pay equalization based on job‑value comparisons.
Dissents or concurrances
Justice Rehnquist (joined by three Justices) dissented, arguing Congress intended the Equal Pay Act's equal‑work standard to control Title VII wage claims and warning against expanding remedies beyond that framework.
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