Background
Sha’ola Terrell appealed the district court’s grant of summary judgment in favor of Alabama State University and its Board of Trustees. Terrell alleged sex-based wage discrimination under the Equal Pay Act and the Clarke Figures Equal Pay Act. She argued she presented proper comparators and that the university’s budget defense failed.
The court’s reasoning
The court applied a two-step framework for Equal Pay Act claims. First, a plaintiff must show that an employer pays different wages for equal work requiring equal skill, effort, and responsibility under similar working conditions. The court found that none of Terrell’s proposed comparators occupied a substantially similar position. One comparator, Terrance Jones, was paid more but had broader duties including overall supervision of the department and unique responsibilities for former student-athletes. Another comparator, Ronald Brown, had duties focused on academic support that were starkly different from Terrell’s. Two other comparators, Derrick Magee and Lonnie Brown, were paid the same amount as Terrell, which precludes a prima facie case. The court noted that a plaintiff’s higher position in the hierarchy is not dispositive if job duties are not substantially similar.
What it means going forward
The decision reinforces that plaintiffs must demonstrate that job duties are substantially similar, not just that they hold a lower position or have different titles, to establish a prima facie case of wage discrimination.
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