Puffer v. Allstate Ins. Co., No. 11-1273 (7th Cir. 2012)
Annotate this CasePlaintiff sued Allstate on behalf of a putative class, alleging a nationwide pattern or practice of sex discrimination in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e, and the Equal Pay Act, 29 U.S.C. 206(d). She alleged gender-based earning disparities based on salary, promotion, and training policies that left significant discretion in the hands of individual managers. The district court denied class certification. In response to enactment of the Lilly Ledbetter Fair Pay Act of 2009, Pub L. No. 111-2, plaintiff again moved for class certification, focusing on Allstate's uniform compensation policies. The court again denied certification, citing lack of common issues. On appeal, plaintiffs argued disparate impact, claiming that a policy of awarding merit increases based on a percentage of base pay and of comparing salaries to its competitors caused gender-based disparities in earnings. The Seventh Circuit affirmed denial of class certification, stating that plaintiffs did not meaningfully develop the disparate impact claim before the district court, where plaintiffs argued only a pattern-or-practice claim, a type of intentional discrimination.
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