Marybeth Lauderdale v. Illinois Department of Human S, 876 F.3d 904

Background

Marybeth Lauderdale served as superintendent of the Illinois School for the Deaf (ISD) and was offered a combined superintendent role covering ISD and the Illinois School for the Visually Impaired (ISVI) after Reggie Clinton resigned.
Lauderdale’s final ISD pay (including bilingual bonus) was $88,048; Clinton’s ISVI pay was $121,116. Lauderdale accepted $106,500 for the combined role (≈21% increase from her prior pay, less than Clinton’s prior pay).
Lauderdale sued under the Equal Pay Act, Title VII, and 42 U.S.C. § 1983 (Equal Protection), alleging sex-based pay discrimination compared to Clinton.
The State explained the pay differential by citing the Illinois Central Management Services (CMS) pay plan, reliance on prior salaries, and budget constraints; the record included CMS classification and a special salary request form and internal emails discussing budget politics.
The district court granted summary judgment to defendants, concluding no reasonable juror could find sex discrimination; the Seventh Circuit affirmed, finding legitimate nondiscriminatory reasons and insufficient evidence of pretext.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Equal Pay Act: Was Lauderdale paid less for equal work because of sex?	Lauderdale: She performed Clinton’s duties (plus ISD duties) and was paid less; Equal Pay Act violation.	State: Pay decision driven by CMS pay plan, prior salaries, and budget constraints (factors other than sex).	Affirmed: Plaintiff made prima facie case, but employer showed legitimate nondiscriminatory factors; no sufficient evidence of pretext.
Title VII: Was pay decision unlawful disparate treatment based on sex?	Lauderdale: Less pay than a male counterpart shows sex discrimination.	State: Same nondiscriminatory reasons (pay plan, prior pay, budget); even if disparity exists, employer’s reason is legitimate.	Affirmed: Plaintiff met initial prima facie elements but failed to show employer’s reasons were pretext for sex discrimination.
§ 1983 / Equal Protection: Did state actors intentionally discriminate on basis of sex?	Lauderdale: State officials (including Governor and staff) participated in salary decision and should be held liable.	State: No evidence individuals acted with discriminatory intent beyond the Department’s nondiscriminatory process.	Affirmed: No evidence to hold individuals liable; insufficient proof of intentional discrimination.
Pretext / Credibility: Are employer’s stated reasons factually baseless or dishonest?	Lauderdale: Points to the published salary range ($126,000) and her deposition where no one told her budget blocked higher pay.	State: Range was maximum guide; record emails, furloughs, and special salary request show genuine budget concerns and reliance on CMS procedures.	Affirmed: Record supports employer reliance on neutral factors; plaintiff failed to create triable issue of pretext.

Key Cases Cited

Hooper v. Proctor Health Care Inc., 804 F.3d 846 (7th Cir. 2015) (summary judgment review and discrimination standard)
Bass v. Joliet Pub. Sch. Dist. No. 86, 746 F.3d 835 (7th Cir. 2014) (reasonable jury inquiry into discrimination)
King v. Acosta Sales & Mktg., Inc., 678 F.3d 470 (7th Cir. 2012) (Equal Pay Act prima facie and employer reliance requirement)
Corning Glass Works v. Brennan, 417 U.S. 188 (U.S. 1974) (burden-shifting and employer defenses under the Equal Pay Act)
Wernsing v. Dep’t of Human Servs., 427 F.3d 466 (7th Cir. 2005) (prior salary as legitimate factor other than sex)
Riordan v. Kempiners, 831 F.2d 690 (7th Cir. 1987) (prior salaries and civil service pay structures do not violate the Equal Pay Act)
Dey v. Colt Constr. & Dev’t Co., 28 F.3d 1446 (7th Cir. 1994) (prior salary as legitimate nondiscriminatory factor)
Covington v. Southern Illinois Univ., 816 F.2d 317 (7th Cir. 1987) (use of prior pay in public employment pay decisions)
St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (U.S. 1993) (burden of proof on pretext in Title VII cases)
Burks v. Wisconsin Dep’t of Transp., 464 F.3d 744 (7th Cir. 2006) (elements for Title VII / § 1983 employment discrimination claims)
E.E.O.C. v. Target Corp., 460 F.3d 946 (7th Cir. 2006) (evidence required to infer employer dishonesty/pretext)
Hayden ex rel. A.H. v. Greensburg Cmty. Sch. Corp., 743 F.3d 569 (7th Cir. 2014) (equal protection requires intentional discrimination)