Sunday, November 24, 2013

American Nurses Association v. Illinois case brief

American Nurses Association v. Illinois case brief summary
783 F.2d 716 (7th Cir. 1986)

Plaintiff state employees, holding jobs filled primarily by women, appealed a decision from the United States District Court for the Northern District of Illinois, Eastern Division, dismissing their complaint under Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause for failure to state a claim.

The state employees contended that the trial court erred in dismissing their complaint for failure to state a claim. The court reversed the trial court's decision and remanded for further proceedings. The complaint charged that defendant State of Illinois had intentionally discriminated by departing from the market measure of salaries on the grounds of sex and that the State of Illinois had violated Title VII of the Civil Rights Act of 1964 by merely failing to pay comparable wages for comparable work.


  • While the latter allegation was not actionable under Title VII, the former allegation was. 
  • The complaint was not to be dismissed merely because it included invalid claims along with a valid one. 
  • However, the requisite proof of intentional discrimination was not to be inferred merely from the results of a comparable worth study and from the refusal of an employer to implement the study's recommendations.
The trial court's dismissal of the state employees' complaint was reversed and the case was remanded.

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