Lenzi v. Systemax, Inc., No. 18-979 (2d Cir. 2019)Annotate this Case
The Second Court clarified that, to establish a prima facie pay discrimination claim under Title VII, a plaintiff need not first establish an Equal Pay Act violation—that is, that she performed equal work but received unequal pay. Rather, all Title VII requires a plaintiff to prove is that her employer discriminated against her with respect to her compensation because of her sex. The court adopted the framework applicable to Sarbanes‐Oxley Act of 2002 whistleblower retaliation claims to Consumer Product Safety Improvement Act whistleblower retaliation claims.
In this case, plaintiff filed suit alleging that defendants paid her less than they would have if she were a man, retaliated against her when she raised concerns about her disparate pay and possible Consumer Product Safety Act violations, and fired her because she was pregnant. The district court held that plaintiff failed to establish a prima facie case for each of her claims.
The court held that there was sufficient evidence to support a prima facie case for plaintiff's Pregnancy Discrimination Act and Title VII claims, but insufficient evidence to support her Consumer Product Safety Improvement Act whistleblower retaliation claim. Accordingly, the court vacated in part and remanded for further proceedings.