Boaz v. FedEx Customer Information Services, Inc.
668 F. App'x 152
| 6th Cir. | 2016Background
- Plaintiff Margaret Boaz sued FedEx under the Equal Pay Act (EPA) and the Fair Labor Standards Act (FLSA), alleging she was paid less than a male colleague (Jim Terrell) for the same work and that she was denied overtime pay. The FLSA claim is not at issue on appeal.
- After a four-day bench trial, the district court entered judgment for FedEx on all claims and denied Boaz’s post-judgment motion. Boaz appealed only the EPA ruling.
- The district court found Boaz had established an EPA prima facie case (different pay for equal work), a fact the parties do not dispute on appeal.
- The district court accepted FedEx’s gender-neutral affirmative defense: a reorganization/reclassification of staff explained the pay differential and was motivated by legitimate business reasons, not sex.
- Boaz argued the district court’s factual findings were clearly erroneous and challenged the credibility of FedEx witnesses; the court of appeals reviewed factual findings for clear error and credibility determinations with deference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pay differential violated the EPA despite employer’s explanation | Boaz: salary disparity shows unlawful sex-based pay discrimination | FedEx: reclassification/organizational change (gender-neutral) caused pay difference for legitimate business reasons | Court: Affirmed — district court did not clearly err; FedEx met affirmative defense |
| Whether appellate court should reject district court credibility/findings | Boaz: witnesses lied; findings are mistaken and should be reversed | FedEx: district court’s credibility findings are entitled to deference; record supports its conclusions | Court: Affirmed — credibility and factual findings not clearly erroneous; deferential review controls |
Key Cases Cited
- Corning Glass Works v. Brennan, 417 U.S. 188 (establishes EPA prima facie framework and burden-shifting)
- Moorer v. Baptist Mem’l Health Care Sys., 398 F.3d 469 (6th Cir. 2005) (bench-trial findings reviewed for clear error)
- Hance v. Norfolk So. Ry. Co., 571 F.3d 511 (6th Cir. 2009) (clarifies standard for reversing under clear-error review)
- Harrison v. Monumental Life Ins. Co., 333 F.3d 717 (6th Cir. 2003) (deference to district court credibility assessments)