Dindinger v. Allsteel, Inc., No. 16-1305 (8th Cir. 2017)Annotate this Case
Plaintiffs Dindinger, Loring, and Freund filed suit against Allsteel, alleging claims of sex-based wage discrimination under the Equal Pay Act, 29 U.S.C. 206(d); Dindinger and Loring also brought claims of sex-based wage discrimination under the Iowa Civil Rights Act, Iowa Code 216.6A, and Title VII of the Civil Rights Act, 42 U.S.C. 2000e; and Loring additionally brought a claim of sex-based discrimination for failure to promote under Title VII. On appeal, Allsteel challenged the district court's denial of its motion for a new trial and grant of plaintiffs' motions for attorney's fees and costs. The court concluded that the district court correctly instructed the jury that Allsteel could not rely on economic conditions to establish its affirmative defense to the Equal Pay Act claim that a factor other than sex justified the pay discrepancies between plaintiffs and their male comparators; even if the court were to agree that economic conditions could be a factor other than sex justifying a pay differential in some circumstances, Allsteel did not present evidence to establish such a defense here; and because Allsteel did not present evidence that economic conditions caused the pay differentials plaintiffs experienced, the district court did not abuse its discretion in instructing the jury that Allsteel could not rely on economic conditions to establish an affirmative defense. The court also concluded that the district court did not abuse its discretion by admitting "me-too" evidence; limiting Allsteel's ability to offer evidence regarding the audit; and by admitting testimony from Loring's supervisor. Finally, the court concluded that the district court did not abuse its discretion in regard to attorney's fees, but remanded the issue of costs with instructions to determine whether charging clients separately for Westlaw research is the prevailing practice in Iowa. Accordingly, the court remanded as to this issue and affirmed in all other respects.