Saturday, November 28, 2015

American Nurses Association v. Illinois case brief summary

American Nurses Association v. Illinois case brief
1986 U.S. Ct of Appeals 7th circuit

Posture: Ct of Appeals reversed and remanded the case to the trial ct. Trial court decided to dismiss complaint. Case began in Illinois federal court.
Facts: Class action against State of Illinois with sex discrimination, the complaint  is a wage complaint. District judge dismissed complaint because it was a comparable worth case which does not violate federal anti-discrimination law. Plaintiff appeals because that was not what the case was about. 

Reasoning: If they really are just complaining about a lack of a comparable worth study to make sure men and women get same pay, then there is no case. Posner wants to look closer at complaint.  A complaint cannot be dismissed merely because it includes invalid claims along with a valid claim. Posner says that when a defendant is unclear about a particular allegation, plaintiff must amend for a more definite statement. Otherwise it would not be fair. He finds that if the government willfully decided not to pay comparable wages because they thought men deserved to pay more, then complaint can exist and survive a motion to dismiss. A complaint is not required to allege all, or even any, of facts logically entailed by claim. 

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