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Garland's Digest
on employment discrimination law
online since 1997
 

 

Disclaimer: The case on which this summary is based may no longer be current law. Also, if the case was decided on summary judgment, the court recited the "facts" in the light most favorable to the non-movant, which may not be the true facts.

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Equal Pay Act claim fails because male comparators were not performing jobs requiring equal skill, effort and responsibility.

Ingram v. Brink's Inc., 414 F.3d 222 (1st Cir. July 15, 2005) - This is a sex discrimination action brought under Massachusetts state law (alleging failure to promote) and under the Equal Pay Act. Kathleen Ingram's state law claims fail. She alleges that she was denied several promotions, but claims under Massachusetts General Laws ch. 151B had to be brought within six months (the time period has since been changed to 300 days) and none of the failures to promote occurred within six months of Ingram bringing her charge. Next, with respect to the Equal Pay Act claim, Ingram had to first establish a prima facie case by showing that the employer paid different wages to specific employees of different sexes for jobs performed under similar working conditions and requiring equal skill, effort and responsibility. Ingram identified two male employees, but neither one was performing comparable work. Therefore, she failed to make out a prima facie case. Click here to see actual case.