Mundell v. Acadia Hospital Corp., No. 22-1394 (1st Cir. 2024)
Annotate this CaseClare Mundell worked as a licensed clinical psychologist for Acadia Hospital in Maine. She discovered that her male colleagues were paid significantly more than her for comparable work. Mundell brought a sex discrimination action against Acadia under federal and state law, specifically the Maine Equal Pay Law ("MEPL"). The district court found Acadia liable under the MEPL and awarded Mundell treble damages. On appeal, Acadia argued that the district court erred in holding that Mundell could prevail without establishing Acadia's discriminatory intent and because Acadia claimed a reasonable-factor-other-than-sex defense to explain the pay difference. The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that the MEPL does not impose an intent requirement on a plaintiff, nor does it permit a defendant to rely on a catch-all affirmative defense such as market factors to explain pay disparity. The court also concluded that treble damages are available for MEPL violations.
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