Sally Randall v. Rolls-Royce Corpor, 637 F.3d 818

Plaintiffs are over 500 female Rolls-Royce Indiana plant employees alleging Title VII sex discrimination and EPA pay discrimination, and promotion denial claims.
District court denied class certification under Rule 23(b)(2) and Rolls-Royce moved for summary judgment on EPA claim; the court resolved merits as to named plaintiffs.
Rolls-Royce uses a two-step pay framework: broad compensation categories with ranges, then market-based narrowing within each category.
Base pay within categories is influenced by market wages and performance-based add-ons; discounts or elevations depend on job market comparisons and supervisor evaluations.
In 2003, average base pay for men in five grades was about 5% higher than women; performance adjustments magnified or reduced total pay across years.
Experts challenged discrimination theory: Rolls-Royce’s expert found no Title VII base-pay discrimination after adjusting for job differences; plaintiffs’ EPA claim failed for lack of equal-work comparators; plaintiffs’ promotion claims were weaker and involve highly senior, non-fungible roles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should the district court certify the class under Rule 23?	Named plaintiffs adequate and typical representation.	Significant differences and conflicts undermine adequacy and typicality.	No; certification upheld as properly denied due to lack of typicality/adequacy considerations.
Is there a Title VII-based base-pay discrimination after market-adjustment analysis?	Base-pay disparity shows discrimination persisting due to sex.	Adjusting for job differences and market should eliminate disparity; no discrimination.	Discrimination claim fails; Siskin's adjustment shows no remaining base-pay disparity attributable to sex.
Does the EPA claim survive given lack of appropriate comparators?	Unpaid wage differential constitutes EPA violation.	Cannot identify male comparator with equal work/skill/responsibility; EPA fails.	EPA claim fails as pleaded due to lack of proper equal-work comparators.
Can substitution of unnamed class members for named plaintiffs salvage certification or relief?	Substitution could restore typicality and adequacy.	Substitution late and improper; would delay and prejudice Rolls-Royce.	Motion to substitute denied; substitution not automatic and timeliness matters.

Bazemore v. Friday, 478 U.S. 385 (U.S. 1986) (concurring opinion on Equal Pay Act/Title VII interplay)
Hildebrandt v. Illinois Dept. of Natural Resources, 347 F.3d 1014 (7th Cir. 2003) (acceptance of certain discrimination theories; adequacy/typicality concerns)
Lang v. Kohl's Food Stores, Inc., 217 F.3d 919 (7th Cir. 2000) (comparable-worth concepts not recognized for federal discrimination suit)
American Nurses’ Ass’n v. Illinois, 783 F.2d 716 (7th Cir. 1986) (limits on discrimination theories and class representation concepts)
Mikula v. Allegheny County, 583 F.3d 181 (3d Cir. 2009) (comparability standards for discrimination claims)
United Auto Workers v. Michigan, 886 F.2d 766 (6th Cir. 1989) (equal pay and job classification considerations)
Thorn v. Jefferson-Pilot Life Ins. Co., 445 F.3d 311 (4th Cir. 2006) (Rule 23(b)(2) adequacy and injunctive relief framework)
Reeb v. Ohio Dep’t of Rehabilitation & Correction, 435 F.3d 639 (6th Cir. 2006) (injunctive relief and monetary tail considerations in certification)
In re Allstate Ins. Co., 400 F.3d 505 (7th Cir. 2005) (monetary relief and class action scope; 23(b)(2) limitations)
Kartman v. State Farm Mutual Auto Ins. Co., 2011 WL 488879 (7th Cir. 2011) (requires final relief under 23(b)(2); not satisfied by purely monetary tail)
Jefferson v. Ingersoll Intl., Inc., 195 F.3d 894 (7th Cir. 1999) (cohesive class actions under 23(b)(2) prerequisites)