Randolph Central School District v. Aldrich

Background

This case involves an employer’s use of the Equal Pay Act defense called the “factor other than sex,” which employers use to justify pay differences. The Court of Appeals for the Second Circuit held an employer cannot meet that defense merely by pointing to a gender-neutral classification system; the employer must show a bona fide business-related reason. Several other federal circuits have reached conflicting results on this question.

Reasoning

The central question is whether an employer must prove that a pay factor is supported by a legitimate business reason. The Second Circuit required such proof. The Eighth Circuit in Strecker allowed objective, duties-related criteria without extra proof that the classifications were bona fide. The Seventh Circuit said the factor need not be related to the job’s requirements or be a business-related reason. The Ninth and Sixth Circuits have offered yet other interpretations. The Supreme Court declined to review the case, and Justice White (joined by the Chief Justice and Justice O’Connor) dissented from that denial and would have granted review to resolve the circuit split.

Real world impact

Because the Supreme Court refused review, the conflict among federal appeals courts remains. In some circuits employers must show a legitimate business reason for pay differences; in others, objective classification systems may suffice without that showing. As a result, whether workers prevail in Equal Pay Act disputes may turn on the federal circuit handling the case.

Dissents or concurrances

Justice White filed a dissent from the denial of review, arguing this is an important, clear-cut legal issue warranting Supreme Court resolution and citing precedents allowing interlocutory review.