Background
Plaintiff Gloria Holladay sued her employer, Gestamp Alabama, LLC, alleging age discrimination under the Age Discrimination in Employment Act, sex discrimination and retaliation under Title VII and the Fair Labor Standards Act, and a violation of the Equal Pay Act. The district court granted summary judgment on all claims except the Equal Pay Act claim, which was settled via a consent judgment. The district court then awarded Holladay attorney’s fees and costs but denied her submission for additional expenses, ruling they were not permitted under Section one thousand nine hundred twenty.
The court’s reasoning
The court reviewed the Title VII and ADEA claims de novo, finding no evidence that sex or age was a motivating factor or but-for cause of termination. Regarding retaliation, the court held that complaints about pay disparity without alleging discrimination did not constitute protected activity. On the Equal Pay Act versus Title VII wage claim, the court affirmed that the Equal Pay Act imposes strict liability while Title VII requires proof of discriminatory intent. The court upheld the reduction of attorney’s fees based on the limited success on a single claim out of six. However, the court found error in denying expenses, noting that the consent judgment explicitly authorized recovery of expenses, distinguishing them from costs under Section one thousand nine hundred twenty.
What it means going forward
Employers may rely on consent judgments that explicitly include expenses to recover litigation costs beyond statutory costs, but must ensure the district court evaluates the reasonableness of those expenses under the contract terms rather than statutory cost limits.