A California appellate panel reversed dismissal of a female employee’s Equal Pay Act (EPA) claim, finding her evidence that a single male comparator was paid more than she was to be sufficient to survive summary judgment.
Employees at Staples received annual salaries based on the grade assigned to their job position, and each grade had a corresponding salary range. The specific salary an employee received was determined by several factors, including time with the company, number of years in the position and performance.
Joyce Allen joined Staples in October 2006 and became an area sales manager (ASM) in 2015. The ASM position was grade 37 with a salary range of $65,000–$135,000.
Staples set Allen’s base salary at $84,999.96 and increased it to $86,912.46 in April 2017. Charles Narlock, another ASM in Allen’s region, had a base salary in grade 37 of $107,698.86—approximately $22,000 more than Staples paid Allen when she started in the position.
During the period in which Allen held her ASM position, there were two other ASMs, a man who earned between $109,999.76 and $111,099.76, and a woman who earned between $124,071.81 and $127,818.78.
Although Staples had fewer women than men who were ASMs in the United States during that period, women were among the highest-earning ASMs and at least six men earned less than Allen.
In July 2017, Allen was promoted to a field sales director (FSD) position, which was a grade 38 with an annual salary range of $80,000–$160,000. Allen’s base...
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