A complaint does not fail to state a claim merely because it does not set forth a complete and convincing picture of the alleged wrongdoing.
State employees, holding jobs filled primarily by women, charged the State of Illinois for intentionally discriminating against women by failing to pay comparable wages for comparable work and departing from the market measure of salaries on the grounds of sex in violation of Title VII of the Civil Rights Act of 1964. The trial court dismissed their complaint for failure to state a claim. The case was appealed to the United States Court of Appeals for the Seventh Circuit.
Where a complaint alleges valid causes of action along with being insufficient for other causes, is the complaint subject to dismissal?
The Court held that while the case was not actionable under the violation of the Civil Rights Act, the case was actionable for discriminating on the ground of sex by departing from the market measure of salaries. The court reasoned that the complaint was not to be dismissed merely because it included invalid claims along with a valid one. However, the requisite proof of intentional discrimination was not to be inferred merely from the results of a comparable worth study and from the refusal of an employer to implement the study's recommendations. The trial court's dismissal of the state employees' complaint was reversed and the case was remanded.