Celesq® Programs

Changing Legal Standards for Bringing Gender-Based Pay Disparity Claims in the Second Circuit

Program Number
Program Date

This program discusses the standard for bringing gender-based pay disparity claims under the Equal Pay Act and Title VII. The program will provide basic background information including a review of the purposes of, the similarities and differences between and the remedies available under both laws. We will then review prior New York federal district and appellate court rulings discussing the legal standards for making a prima facie case of discrimination under the Equal Pay Act and Title VII. Specifically, we will discuss how prior to a Second Circuit decision in late 2019 clarified the law, New York federal courts were conflating the legal standards for bringing a Title VII claim with an Equal Pay Act claim. Further, we will discuss how by conflating these standards, courts left certain claimants with otherwise legitimate gender-based pay disparity claims with no legal remedy. Finally, we will review the Second Circuits December 2019 decision in Lenzi v. Systemax, 944 F.3d 97 (2d Cir. 2019), which clarified the standard for bringing a Title VII gender-based pay discrimination claim, likely making it easier for a plaintiff to bring such claims.

Available in States

  • California
  • Georgia
  • New Jersey
  • New York
  • Texas Self Study

Program Categories

  • Administrative Law & Regulations
  • Constitutional Law
  • Diversity, Inclusion and Elimination of Bias
  • Elimination of Bias--Special ethics
  • Employee Benefits & Compensation
  • Federal Courts
  • Labor & Workforce Management Law
  • Labor Law
  • Regulatory and Administrative Law