Senate Health, Education, Labor and Pensions Committee Hearing
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Good afternoon Mr. Chairman and members of the Committee. On behalf of the
I am also a partner with the law firm of
In today's testimony n3 I discuss the meaning and impact of the Act on the Equal Pay Act of 1963 n4 ("
On the unsupported assertion that women today earn
Instead, in practice, the Act would: (1) impose enormous burdens and risks on employers who base compensation decisions on factors other than sex such as training, experience and education, or reliance on the current market value placed on skills and experience and economic need, (2) devalue in the marketplace enhanced skills, training and experience (as well as other non-discriminatory factors for pay differences between employees), and (3) expand litigation opportunities for class action lawyers seeking millions of dollars from companies without ever having to prove that the companies intentionally discriminated against women.
The proposed changes to the
Commentators and courts have often referred to this leniency in the
And, if the Act becomes law, a plaintiff could erase an employer's defense and leave it open to a jury award of unlimited punitive and compensatory damages in large mass actions on the basis of one employee's complaint (without regard to the size of the employer). Under the Act, employer liability attaches every time a plaintiff's lawyer shows an employer could have implemented an alternative employment practice that would serve the same business purpose without producing a differential in pay between a male and female employee. This is true even where the employer shows that the factor other than sex justifying the differential in pay is education, training, or experience. The Act does not describe any examples of alternative employment practices that would suffice to defeat the employer's burden. If a plaintiff countered an employer's justification of education, training, or experience by suggesting that the employer had the financial ability to raise everyone's pay in the same job - is that alternative an alternative employment practice that would defeat the employer's defense (in every case, so that the Act's "factor other than sex" defense is in fact a complete illusion)? In effect, the Act suggests that the universal alternative will be to "round up" any wage distinction. No answer is found in the Act; yet, there is no question that this one issue will lead to considerable uncertainty and litigation.
The Act's elimination of the
For these reasons, and all of the reasons set forth below, the Chamber strongly opposes the Paycheck Fairness Act. We urge the Committee to carefully consider the issues raised by the Chamber and proceed cautiously in considering the Act.
Current Protections Against Sex-Based Wage Discrimination
Overview
Since 1963, it has been unlawful under the
Today, the
Mechanics of the
The
The
To prevail under the
The
Title VII
Similarly, under Title VII, it is "an unlawful employment practice for an employer . . . to discriminate against any individual with respect to [her] compensation . . . because of such individual's . . . sex . . . ." n21 An employee may assert a claim for sex-based pay discrimination by filing a charge of discrimination with EEOC and then, upon receipt of her notice of right to sue (and regardless of whether EEOC finds "cause" for concluding that discrimination occurred), may file a lawsuit in federal court. Further, an employee need not engage an attorney to participate in the EEOC processes, including investigation of their allegations of discrimination under the
To establish that similarly-situated males were more favorably compensated, as is necessary to prevail in a disparate treatment pay claim under Title VII, a plaintiff must either provide direct evidence of discrimination, or prove discrimination through the indirect method by providing evidence of a prima facie case of discrimination. Once she has done so, the employer must articulate a legitimate, non-discriminatory reason for the wage differential. At that juncture, the plaintiff has an opportunity to prove that the proffered reason is a pretext for unlawful employment discrimination. The plaintiff's burden is higher under Title VII in connection with discrimination-based pay claims than under the
Comparison of
Both the
. Under the
. Establishment of the prima facie case of pay discrimination under the
. The
. There is a much longer, more generous limitations period (2 years for a general violation, 3 years for a violation found to be willful) under the
. Under the
The
. Plaintiffs may recover attorneys' fees and costs;
. The EEOC may bring public suits to enforce the
. Plaintiffs may file a charge alleging a violation of the
In the aggregate, these overlapping non-discrimination statutes provide employees multiple avenues for pursuing claims of unequal pay for equal work. They also provide employees with multiple forms of redress with respect to alleged pay discrimination, including: a direct right to a jury trial on their own behalf in federal court, the filing of a charge of discrimination with the EEOC, the right to have the EEOC pursue a claim on their behalf in federal court, and the right to bring a collective action or class action on behalf of other similarly-situated employees who choose to participate in an action under the
And, of course, notwithstanding the differences between the statutes, claimants may bring parallel claims under the
Concerns Regarding Proposed Changes to the Equal Pay Act
Inappropriate Expansion of EPA Remedies For Unintentional Wage Discrimination to Include Unlimited Compensatory and Punitive Damages
Critics of the
In passing the Civil Rights Act of 1991,
Mrs. SCHROEDER. Mr. Chairman, I want to answer some of the things that we have just heard. We are hearing here that there is something wrong with this bill because there are remedies .... Let me tell Members one more thing about punitive damages. You do not get punitive damages unless there was intent. It is all equitable, unless there is intent. It seems to me in this country that if there is intent to discriminate, then we certainly should be out trying to assess some kind of punitive damages. Otherwise, someone just assigns it as a cost of doing business. n26
As evidenced by the above, compensatory and punitive damages serve distinct and specific purposes. Compensatory damages are "intended to redress the concrete loss that the plaintiff has suffered by reason of the defendant's wrongful conduct." n27 Punitive damages are "intended to punish the defendant and to deter future wrongdoing." n28 Under Title VII, "[A] finding of liability does not of itself entitle a plaintiff to an award of punitive damages." n29 "The purpose of awarding punitive damages is to 'punish a wrongdoer for his outrageous conduct and to deter others from engaging in similar conduct.'"). n30 "Such an award must be supported by the record, and may not constitute merely a windfall for the plaintiff." n31 It strains logic and flouts the entire body of federal anti-discrimination law to suggest - or, as the Act would do, to mandate - that damages conceived and intended to punish and deter wrongful conduct should apply to claims of inadvertent, unintentional conduct that has the effect of violating the
In sum, it is inappropriate here to amend the
De Facto Elimination of the "Factor Other Than Sex" Affirmative Defense
Perhaps the most significant substantive revision to the
The
We want the private enterprise system, employer and employees and a union . . . to have a maximum degree of discretion in working out the evaluation of the employee's work and how much he should be paid for it. . . . Yes, as long as it is not based on sex. That is the sole factor that we are inserting here as a restriction. n32
So, clearly, just as important to the
Today, the "factor other than sex" affirmative defense forms the crux of the
The Act would effectively eliminate the
In addition, an employer who determines to pay an applicant or an employee a higher wage based on market forces --i.e. matching a higher pay offer from a competitor --does so at considerable peril. Under the Act, payment of a wage rate as a result of a market condition is unacceptable unless an employer can prove all of the above plus that the market rate of its competitor is "not based upon or derived from a sex-based differential in compensation". How does a small employer demonstrate the absence of sex-based discrimination in its competitor's setting of wages when faced with an imminent decision as to whether to match the pay rate or lose a valuable employee? The Act provides no guidance.
And, finally, having passed each of the above hurdles for every individual wage decision, an employer remains liable for a violation of the Act, if a plaintiff responds to the job-related, business necessitated prior job experience, prior training, or education reason for the higher starting wage rate for the male applicant by "demonstrat[ing] that an alternative employment practice exists that would serve the same business purpose without producing such differential and that the employer has refused to adopt such alternative practice." n36 If an employee demonstrates that an employer was not required to employ a worker with the most experience in the business, or has the financial ability to pay all employees in that position a higher starting wage rate, does the employee satisfy this burden and eliminate the employer's defense? The Act provides no guidance.
Having shown an employer could have adopted another employment practice instead of paying a male applicant a higher wage rate because of their greater experience, education or training, the Act seals the liability of the employer for unlimited compensatory and punitive damages for paying a male applicant a higher wage rate that was job-related, consistent with business necessity, and not the result of sex discrimination, because in retrospect, years later, a jury determined it could have chosen an alternative employment practice.
If the Act were law, it would be imprudent and highly risky for an employer to ever reward applicants or employees in a job title for their individual educational, training, or experience, n37 without providing that same reward to all employees in the job, regardless of their inferior business-related qualifications. Yet, what is the purpose of compensation? Is it to fairly compensate employees for work performed as well as to enable employers to attract the skills and experience necessary to promote the enterprise? The Act looks to the first concept (though it minimizes the importance of education, experience and training by saddling any wage payment differential based on these examples with other prerequisites before they can be used to justify a wage increase), but ignores the second. By placing an employer's decision to value intangible skills and experience under a business necessity test, the Act motivates employers to lean toward compensation practices of an earlier industrial age where many jobs were fungible and skills and education were not regarded as valuable. These concepts have long since been rejected, but the Act will resurrect them as national policy.
As such, the Act places judges and juries in the human resources offices of American businesses to determine whether sex-neutral factors were appropriate considerations - and appropriately considered in an employer's wage-setting decision-making. As the
Application of A Disparate Impact Defense to EPA Disparate Treatment Claim is Inappropriate
Section 3(a) of the Act would alter the "factor other than sex" affirmative defense by requiring employers to prove, in order to counter the presumption of wage discrimination, that the factor responsible for a wage differential is a bona fide factor other than sex, job related, consistent with business necessity, and is not based upon or derived from a sex-based differential in compensation.
The job-related and consistent with business necessity defense, however, is an offshoot of disparate impact law under Title VII, intended to address the effects of an employer's neutral policies that disproportionately impact a protected group. n39 A helpful key to explaining the improper application of the business necessity standard to
Courts have long held that these frameworks are not compatible. In Wernsing, the Seventh Circuit found that "[a]n analogy to disparate-impact litigation under Title VII does not justify a "business reason" requirement under the Equal Pay Act, however, because the Equal Pay Act deals exclusively with disparate treatment. It does not have a disparate impact component." n41 As the Ninth Circuit explained in Spaulding v.
The [disparate impact] model was developed as a form of pretext analysis to handle specific employment practices not obviously job-related . . . As the court in Pouncy v.
Attaching a disparate impact framework onto a disparate treatment claim is fundamentally illogical, because it removes the intermediary step of identifying the practice or policy, whose application allegedly serves as the basis for the assertion of employer discrimination. In other words,
It is important to note that the plain text of Act proposes to apply the "bona fide" determination to factors including education, training, or experience. And where such tests have been permitted by courts in pay discrimination cases under Title VII, the question has always pertained to a limited threshold test: whether the non-discriminatory factor is truly necessary and inseparably intertwined with the performance of duties and responsibilities of a job. In other words, Title VII applies the business necessity test to questions that result in a binary answer: either a factor is necessary to job performance or it is not. For instance, the Griggs court found that a high school diploma was not necessary to job performance; and it is from this business necessity showing that courts infer whether defendants are able to produce explanations that are "bona fide" factors, rather than merely a pretext for discrimination that would exclude certain groups. In that sense, the business necessity test as established by the Griggs court and applied to Title VII claims since then upholds the equality of opportunity explicitly protected by the Civil Rights Act and implicitly promised by the principles that have guided this country since its founding.
In contrast, the Act would now apply standards of job-relatedness and business necessity to questions that require economic valuations of an unlimited number of factors. The Act essentially invites employees and employers to dispute in court whether certain qualifications, including education, training, or experience, are justifications for disparities in compensation. In that sense, the Act represents an unprecedented intrusion of government into the independent business decisions of private enterprises by eroding the fundamental purpose of compensation; n43 in reality, compensation functions not only as a means to remunerate employees for work performed, but also to enable employers to attract the skills and experience likely to promote the competitiveness of the enterprise. In contrast to its usage in Title VII and
The
Section 3(c)(4) of the Act allows an action brought to enforce section 6(d) to be maintained as a class action under the Federal Rules of Civil Procedure. Like multi-plaintiff actions under the FLSA and the ADEA,
Under Rule 23, to bring a class action a plaintiff must first meet all of the "strict requirements" of Rule 23(a) and at least one of the alternative requirements of Rule 23(b). Under Rule 23(a) a plaintiff must show: the class is too numerous to join all members; there exist common questions of law or fact; the claims or defenses of representative parties are typical of those of the class members; and the representative parties will fairly and adequately represent the class. Once these requirements are satisfied, a plaintiff must also satisfy one of the subsections of Rule 23(b). Rule 23(b) requires that a plaintiff show either: that prosecution of individual actions would result in inconsistent holdings or that adjudications would be dispositive of the interests of those not named in the lawsuit, that the party opposing the class has acted on grounds applicable to the entire class making relief appropriate for the class as a whole, or that questions of law or fact common to the members of the class predominate over questions affecting only the individual members of the class and that certification is superior to other available methods for fairness and efficiency purposes. When conducting the required analysis under Rule 23, courts must perform a "rigorous analysis" of plaintiff's ability to meet each of Rule 23's requirements. n44
Conversely, under Section 216(b), while some courts use the Rule 23 approach to the extent those elements do not conflict with Section 216 (such as numerosity, commonality, typicality and adequacy of representation), many courts use a less stringent standard, requiring plaintiff to show only that she is similarly situated to other employees. n45 The similarly situated requirement is met through allegations and evidence of class wide discrimination. Courts generally apply a lenient standard to conditional certification of an
Courts regularly face and grant requests to certify both Federal Rule of Civil Procedure 23(a) class actions alleging wage disparity based on sex, as well as Rule 216(b) collective actions under the
Other Concerns
In addition to the concerns discussed above, the Act raises other serious concerns. Some of those concerns are noted below:
Reinstatement of
Section 9(b)(3) of the Act reinstates the
Data Collection Requirements and Regulations
In 2010, the EEOC requested that the
OFCCP Program Initiatives
Under the innocuous title "Reinstatement of Pay Equity Programs and Pay Equity Data Collection," Section 9 of the Act instructs the Director of the OFCCP to ensure that OFCCP employees, among other things, use a full range of investigatory tools and not to require a multiple regression analysis or anecdotal evidence in a compensation discrimination case. In 2006, the OFCCP adopted two enforcement guidance documents, commonly known as the "Compensation Standards" and "Voluntary Guidelines." Among other items, the Compensation Standards only compared "similarly situated individuals," required OFCCP to use multiple regression analysis, and required that statistical showings be supported with anecdotal evidence of discrimination. Effective
Two provisions are worth particular note: the provisions relating to the agency's analysis of systematic compensation discrimination and the provisions targeted toward surveying the federal contractor community. n59
Section 9 of the Act appears to be designed to statutorily mandate that the OFCCP refrain from requiring the adoption of multiple regression analysis or anecdotal evidence for a compensation discrimination case, among other things. Notwithstanding that the OFCCP recently rescinded the above-noted 2006 Compensation Standards and Voluntary Guidelines, the Chamber opposes the utilization of pay grade analysis as a method for proving that systemic compensation discrimination exists for one very simple reason: it doesn't work. Assuming individuals in the same pay "band" are similarly situated is simply too crude a statistical tool. Multiple regression analysis, on the other hand, is the widely accepted method by which plaintiffs and defendants make their case. Robust statistical tools like this are necessary to analyze the many factors that determine compensation and determine whether pay differentials are due to discrimination or some other factor. Statistical techniques will result in the OFCCP alleging discrimination more frequently, without adequate proof, forcing employers to unnecessarily incur legal costs and wasting OFCCP's resources. One perverse result of making such a change will be that employers will choose to settle with OFCCP based on such an inadequate statistical analysis would open themselves up to charges of reverse discrimination under Title VII or state law. n60
Section 9(b)(3) appears to statutorily mandate the OFCCP equal opportunity survey. It should be noted that the OFCCP's survey, which was intended to help identify federal contractors that should be audited by the OFCCP, was substantively flawed, failed to serve as a useful enforcement tool of the agency, and placed a significant, unnecessary burden on contractors. Years ago, a neutral study of the survey was conducted by
Permitted Inquiries About Wages
Section 3(c) of the Act appears to provide an unprecedented broad right to employees under the
For example, under the NLRA, non-unionized employees have the right to discuss their own wages with other employees, but do not otherwise have the right to obtain written documentation about the wages of any other employees. Although unionized employees, as part of an employer's duty to bargain in good faith, have the right to inquire about wage information for bargaining purposes, this right is not without boundaries and not without safeguards. In
New Definition of "Establishment"
Section 3(a) of the Act appears to redefine and expand the definition of equal work, by amending the
Conclusion
In conclusion, the Chamber has serious concerns with the Paycheck Fairness Act. Mr. Chairman and members of the Committee, we thank you for the opportunity to share some of those concerns with you today. Please do not hesitate to contact me or the Chamber's Labor, Immigration, and Employee Benefits Division, if we can be of further assistance in this matter.
n1 In
n2
n3 I would like to acknowledge
n4 29 U.S.C. [Sec.] 206(d)(1).
n5 The proponents of the Act have not cited any evidence establishing that a wage gap is actually caused by employer discrimination. They essentially propose acceptance of the existence of the wage gap as presumptive proof. However, this unsubstantiated syllogism does not withstand scrutiny. As labor economists and feminist scholars have observed, any wage gap between men and women is attributable to a number of factors bearing no relationship whatsoever to alleged employer discrimination. See, e.g., BUREAU OF LABOR STATISTICS REPORT 1045, HIGHLIGHTS OF WOMEN'S EARNINGS (2013); JOINT ECON. COMM., INVEST IN WOMEN, INVEST IN AMERICA (2010); and AN ANALYSIS OF REASONS FOR THE DISPARITY IN WAGES BETWEEN MEN AND WOMEN Commissioned by the U.S. Dep't of Labor,
The so-called gender wage gap ignores the complexity and documented factors that have been identified in social science research to explain the differences in wage rates between men and women, including the following differences: the availability of other non-economic benefits provided by the employer; an employees' willingness and ability to negotiate pay; pay history; the number of hours worked; an employee's willingness to work during certain shifts and in certain locations; certifications and training obtained by the employee; the amount and type of education achieved; prior experience; length of time in the workforce; length of service with the employer; time in a particular job; the frequency and duration of time spent outside the workforce; job performance; personal choices regarding other family or social obligations; occupational choice, self-selection for promotions and the attendant status and monetary awards; and other "human capital" factors. Many of these factors are a function of personal choices employees make. Reliance on this figure as sufficient evidence of widespread employer discrimination in today's workforce runs counter to every facet of the long-held standard of equal pay for equal work.
n6 Revisions to the "factor other than sex" defense would render it a nullity, allowing judges and juries to second guess employers and the marketplace as to the relative worth of job qualifications in individual pay decisions. The Act, in effect, requires employers to implement a civil service philosophy with respect to all pay decisions, eliminating individual pay advancements unless an employer can prove its pay raise was a business necessity and it cannot be shown that a different economic decision could have been implemented that would not have caused a wage differential for female employees without the pertinent job qualifications.
n7 Title VII of the Civil Rights Act of 1964, 42 U.S.C. [Sec.] 2000e, et seq, as amended by the Civil Rights Act of 1991, PL 102-166, 105
n8 Indeed, the Government's experience with wage setting finds its genesis with the War Labor Board in
n9 29 U.S.C. [Sec.]
n10 Title I of the Americans with Disabilities Act of 1990 ("
n11 42 U.S.C. [Subsec.] 1981 and 1983, respectively.
n12 Under the Act, market forces would effectively be excluded from consideration when an employer sets an individual's pay rates unless an employer is able to prove a negative --that the market rate used was not derived or influenced by a sex-based differential in pay. Under the Act, an employee's request for higher pay to match a competitor's offer could not be "matched" unless, first, the employer proved the competitor's offer was not influenced by a sex-based differential (practically, a very difficult burden) and second, the employee's increase was a business necessity (how does an employer prove that one employee's retention is a business necessity?).
n13 In 1986, the EEOC issued detailed regulations entitled "EEOC's Interpretations of the Equal Pay Act," 29 CFR [Sec.] 1620, as amended. In 2006, the EEOC issued regulations under the
n14 Exec. Order No. 11,246, Section 202(1), 30 Fed. Reg. 12,319 (
n15 29 U.S.C. [Sec.] 206(d).
n16 29 U.S.C. [Sec.] 206(d)(1); Fallon v.
n17 29 U.S.C. [Sec.] 206(d)(1).
n18 See 29 U.S.C. [Sec.] 206(d)(1) (making clear only relevant inquiry is whether alleged disparity resulted from "any factor other than sex"); Mickelson v. New York Life Ins. Co., 460 F.3d 1304, 1310-11 (10th Cir. 2006).
n19 29 U.S.C.
n20 29 U.S.C. [Sec.] 216(b).
n21 42 U.S.C. [Sec.] 2000e-2(a). See also 42 U.S.C. [Sec.] 2000e-2(h).
n22 King v.
n23
n24
n25 Pollard v.
n26 101 CONG. REC. S. 1745 (daily ed.
n27 Cooper Indus., Inc. v.
n28 Id. (citing Gertz v.
n29 Yarbrough v.
n30 Id. (internal citations omitted).
n31 Id. (internal citations omitted).
n32 109 CONG. REC. 9198 (1963) (statement of Rep. Goodell, principal exponent of the Act).
n33 See, e.g., Fallon v.
n34 See, e.g., Aldrich v. Randolph Cent. Sch. Dist., 963 F.2d 520, 525 (2d Cir. 1992); EEOC v.
n35
n36 S. 84, 113th Cong. (2013-2014).
n37 For example, under this replacement for the factor other than sex affirmative defense, an employer who wishes to pay a higher wage to an employee who has five years more experience than another employee may not be able to do so because a court finds that the differential in experience could be overcome by in-house training over an extended period of time. That is a judgment that employers should have an ability to retain in order to have an effective, efficient workforce and in order to achieve their own specific business objectives and priorities.
n38 Sims-Fingers v.
n39 See 42 U.S.C. [Sec.] 2000e-2(k)(1)(A)(i)-(ii) which provides "a complaining party demonstrates that a respondent uses a particular employment practice that causes a disparate impact on the basis of race, color, religion, sex, or national origin and the respondent fails to demonstrate that the challenged practice is job related for the position in question and consistent with business necessity or the complaining party makes the demonstration described in subparagraph (C) with respect to an alternative employment practice and the respondent refuses to adopt such alternative employment practice." Notably, the job-related and consistent with business necessity defense was left undefined in the Civil Rights Act of 1991.
n40 See 42 U.S.C. [Sec.] 2000e-2(k)(1)(B)(i), which provides that "the complaining party shall demonstrate that each particular challenged employment practice causes a disparate impact . . ."
n41 427 F.3d 466, 469 (7th Cir. 2005). See also Smith v. City of Jackson, 544 U. S. at 239 n.11 (2005) (noting in
n42 740 F. 2d 686 (9th Cir. 1984) (overruled on other grounds). See also
n43 The Act's business necessity test takes standards of rigor designed to measure and justify the impact of a specific policy to bar certain groups from access to employment and impose the same standards on individualized compensation decisions. As such, the Act improperly thrusts onto the judiciary an untold number of fact-finding exercises with respect to whether certain qualifications result in incremental performance gains that justify the challenged pay differential. For example, if a law degree is not necessary to the performance of duties and responsibilities of a policy analyst, Title VII will provide appropriate protection if it is used as an inappropriate barrier to employment. However, application of the Act would place members of this legislative body at risk for unlimited damages for paying a higher salary to a male analyst with a law degree as well as a Master of Public Policy degree in comparison with a female analyst without a law degree. In response, the hypothetical defendant would bear the burden of showing that the second degree is indeed a bona fide factor that justifies added compensation, and would face the risk of a judicial body determining otherwise, or determining that, even if so, there was another employment decision that could have been made that would lead to a lesser pay differential between the two policy analysts (i.e. paying both the same pay regardless of the fact one had different qualifications). However, the Act invites such disputes into courtrooms, forcing the judiciary to weigh the merits of the economic judgments of employers.
n44 See e.g., Rhodes v.
n45
n46 Portal-to-Portal Pay Act, 29 U.S.C. [Sec.] 256(b); Allen v. Atl.
n47 See, e.g., Jarvaise v.
n48 See, e.g., Rochlin v.
n49 The stated objectives of the
n50 Affirmative Action and Nondiscrimination Obligations of Contractors and Subcontractors, 71 Fed. Reg. 53,033 (
n51 Id.
n52 Id.
n53 Id.
n54 Id.
n55 See PANEL ON MEASURING AND COLLECTING PAY INFORMATION FROM U.S. EMPLOYERS BY GENDER, RACE, AND NATIONAL ORIGIN ET AL., COLLECTING COMPENSATION DATA FROM EMPLOYERS, (
n56 Id. at 2.
n57 Id.
n58 Id.
n59 A full discussion of these issues is beyond the scope of this testimony. Extensive comment by the Chamber on related issues is available on the Chamber's web site at: www.uschamber.com.
n60
n61 265 NLRB 638 (1982).
n62 29 C.F.R. [Sec.]1620.9(a).
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