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Aldrich v. Randolph Cent. School Dist.

United States Court of Appeals for the Second Circuit

October 10, 1991, Argued ; May 5, 1992, Decided

Docket No. 91-7566


 [*522]  OAKES, Chief Judge:

Cora Aldrich appeals from a judgment entered in the United States District Court for the Western District of New [**2]  York, Richard J. Arcara, Judge, granting summary judgment for defendants Randolph Central School District and Cattaraugus county Civil Service Commission on her claims of sex-based wage discrimination in violation of the Equal Pay Act, 29 U.S.C. § 206(d) (1988), and Title VII of the civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a)(1) (1988), and unlawful retaliation for filing a claim with the New York State Division of Human Rights in violation of 42 U.S.C. § 2000e-3(a) (1988). The district court properly granted summary judgment on Aldrich's Title VII claims of sex-based wage discrimination and retaliation. We conclude, however, that the district court erred by holding that defendants' use of the civil service examination and classification system provides a defense to Aldrich's claim under the Equal Pay Act based on the existing record. Accordingly, we reverse in part and remand.

The Randolph Central School District employs cleaners and custodians to maintain the two buildings used by the Randolph Central School System. In making employment decisions, Randolph must comply with local civil service laws administered by the Cattaraugus County Civil Service Commission. The commission [**3]  establishes job classifications, administers civil service examinations, and prepares eligibility lists for civil service positions.

Cora Aldrich began working as a full-time cleaner in the Randolph Central School District's elementary school in September 1982. The cleaner position is a labor class position. As a result, Randolph may hire anyone it believes can learn to perform the duties of a cleaner in accordance with the job description developed by the commission. All of the cleaners who work in the Randolph Central schools are women.

Aldrich works alongside two male custodians. The custodian position is a competitive position under civil service rules. Applicants for the position must take a civil service examination. Their scores are ranked and placed on an eligibility list. Randolph may only hire custodians from among the top three applicants on the eligibility list. Men and women are equally eligible to apply for custodian and cleaner positions. Custodians are paid higher wages than cleaners.

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963 F.2d 520 *; 1992 U.S. App. LEXIS 9833 **; 58 Fair Empl. Prac. Cas. (BNA) 1373; 121 Lab. Cas. (CCH) P35,642; 58 Empl. Prac. Dec. (CCH) P41,477; 30 Wage & Hour Cas. (BNA) 1457

Cora Aldrich, Plaintiff-Appellant, v. Randolph Central School District and Cattaraugus County Civil Service Commission, Defendants-Appellees.

Subsequent History: As Amended May 12, 1992. Second Amendment June 2, 1992.

Prior History:  [**1]  Appeal from a judgment of the United States District Court for the Western District of New York, Richard J. Arcara Judge, granting defendants' motion for summary judgment on claims of sex-based wage discrimination in violation of the Equal Pay Act and Title VII of the Civil Rights Act of 1964 and retaliation in violation of Title VII.

Disposition: Affirmed in part, reversed in part, and remanded.


school district, equal pay, cleaner, sex, district court, job classification, civil service examination, factor-other-than-sex, summary judgment, sex-based, male, civil service commission, differential, retaliation, grant summary judgment, classification system, classifications, exam, wage differential, bona fide, job-related, hire, civil service classification, defenses, performs, job-relatedness, discriminate, classified, conditions, disparate

Civil Procedure, Judgments, Summary Judgment, Evidentiary Considerations, Entitlement as Matter of Law, General Overview, Appropriateness, Genuine Disputes, Legal Entitlement, Materiality of Facts, Appeals, Standards of Review, De Novo Review, Summary Judgment Review, Standards of Review, Labor & Employment Law, Gender & Sex Discrimination, Employment Practices, Compensation, Equal Pay, Equal Pay Act, Burdens of Proof, Evidence, Burdens of Proof, Gender Neutral Practices, Employee Burdens, Wage & Hour Laws, Defenses, Discrimination, Title VII Discrimination, Disparate Impact, Disparate Compensation, Selection Procedures, Neutral Factors