94 F.4th 1312
11th Cir.2024Background
- Dr. Baker, a female OB-GYN, was hired full-time by Upson Regional Medical Center in 2015, with less than three years of experience and no board certification at hiring.
- Dr. Psomiadis, a male OB-GYN, was hired around the same time, but had 15 years of experience, board certification, and an unblemished record.
- Baker’s compensation structure initially offered a lower base salary and different bonus (wRVU) structure compared to Psomiadis.
- Baker later renegotiated her contract to match Psomiadis’s bonus structure, but claimed the earlier disparity constituted discrimination under the Equal Pay Act (EPA) and Title VII.
- The district court granted summary judgment for Upson, finding legitimate, non-sex-based reasons for pay differences, and dismissed Baker’s Title VII claims as either abandoned or untimely.
- On appeal, the Eleventh Circuit affirmed, but clarified the proper framework for EPA claims and noted a partial dissent regarding adequacy of the employer's showing at summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Correct EPA Standard | Lower court misapplied EPA by requiring plaintiff to prove pretext | Precedent required plaintiff to rebut with pretext | Court clarifies EPA follows strict 2-step: no pretext; employer must fully prove affirmative defense |
| Justification for Pay Disparity | Disparity not justified; no evidence bonus differences were not sex-based | Disparity based on experience, certification, and not sex | Court finds record supports legitimate, non-sex factor justification |
| Summary Judgment on EPA Claim | Employer did not meet heavy burden; insufficient evidence | Thompson's testimony and undisputed factual differences suffice | Majority: burden met, no triable fact; Dissent: evidence insufficient—summary judgment improper |
| Title VII Claims | Dismissal improper | Claims were abandoned/untimely | Court finds Title VII claims not preserved on appeal—affirmed |
Key Cases Cited
- Corning Glass Works v. Brennan, 417 U.S. 188 (clarifies EPA framework: two steps, not requiring proof of intent)
- United States v. Four Parcels of Real Prop., 941 F.2d 1428 (summary judgment standards and burden allocations)
- County of Washington v. Gunther, 452 U.S. 161 (distinguishes elements of EPA and Title VII pay claims)
- Mitchell v. Jefferson Cnty. Bd. of Educ., 936 F.2d 539 (EPA is strict liability, not intent-based)
- Miranda v. B & B Cash Grocery Store, Inc., 975 F.2d 1518 (outlines two-step EPA analysis and differences from Title VII)
- Fitzpatrick v. City of Atlanta, 2 F.3d 1112 (summary judgment shifting burdens framework)
- Meeks v. Comput. Assocs. Int’l, 15 F.3d 1013 (contrasts the burdens in EPA and Title VII claims)