ANITA EISENHAUER, Plaintiff-Appellant, v. CULINARY INSTITUTE OF AMERICA, Defendant-Appellee., 84 F.4th 507

Summary

HOLDINGS: [1]-An employer established that it did not violate the Equal Pay Act (EPA), 29 U.S.C.S. § 206, because the pay disparity between the female plaintiff and a similarly situated male employee was based on a factor except for sex since the pay disparity resulted entirely from disparate starting salaries and the formulaic application of a compensation plan, which was incorporated in a CBA, and which the employer applied uniformly to other employees, male and female, and the terms of the compensation plan were sex neutral since the pay increases recognized the skill, experience, or added value associated with employees' additional degrees or academic promotions; [2]-However, the district court erred in its ruling under N.Y. Lab. Law § 194(1) because it did not consider the fact that § 194(1) included a job-relatedness requirement to this defense, which differed from the EPA.