55 F.4th 1155
8th Cir.2022Background
- Mayorga was hired as a general cleaner by Marsden (2013), left (2014), then returned (2018) at $12/hour; later served also as assistant manager inspecting other cleaners.
- After a 2019 leave, Marsden offered her a special services position (pay listed $13–$15) though Marsden intended to keep her at $12/hour until she was trained or another opening arose.
- Marsden hired two male special-services employees (Wright at $13/hr, Cabezas at $14/hr) who had substantially more prior special‑services experience and machine operation skills.
- Mayorga requested a raise to $13/hr in February 2020; after a heated meeting with operations manager Velasquez she was told she was fired.
- She filed an administrative complaint, then sued under the Iowa Civil Rights Act for wage discrimination, sex discrimination, and retaliation; district court granted summary judgment for Marsden, and Mayorga appealed as to wage and sex discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Wage discrimination (ICRA §216.6A): whether Mayorga was paid less because of sex | Mayorga: paid less than male coworkers doing substantially equal work | Marsden: pay differences based on prior experience (a non‑sex factor) | Court: Affirmed for Marsden — experience justified pay differential |
| Sex discrimination (termination) (ICRA §216.6(1)(a)): whether termination was motivated by sex | Mayorga: Velasquez fired her, allegedly because he "could not tolerate being challenged by a woman" | Marsden: termination lacked evidence of sex‑based motive; no direct evidence or comparator proof | Court: Affirmed — no reasonable inference of sex discrimination; prima facie element not met and no pretext shown |
Key Cases Cited
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment standard)
- Martinez v. W.W. Grainger, Inc., 664 F.3d 225 (summary judgment review in Eighth Circuit)
- Dindinger v. Allsteel, Inc., 853 F.3d 414 (elements for ICRA wage claim)
- Hunt v. Neb. Pub. Power Dist., 282 F.3d 1021 (substantially equal work principle)
- Taylor v. White, 321 F.3d 710 (employer must prove pay differential based on factor other than sex)
- Hutchins v. Int’l Bhd. of Teamsters, 177 F.3d 1076 (education/experience as factor other than sex)
- Schottel v. Neb. State Coll. Sys., 42 F.4th 976 (experience supporting nondiscriminatory pay differential)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination claims)
- Price v. N. States Power Co., 664 F.3d 1186 (summary judgment and ICRA wage‑claim framework)