Every example below is a fictionalized composite created for educational purposes. The employees, employers, and facts are invented and do not represent any real person, company, or case. These examples are general public information, not legal advice.
- Fictional employee
- U.J., machine operator
- Fictional employer
- Harborview Transit Group
- Location
- a metro area in the South
- Illustrated statute
- the Equal Pay Act and Title VII
Illustrative charge narrative
I was employed by Harborview Transit Group as a machine operator in a metro area in the South. I performed work equal in skill, effort, and responsibility, under similar working conditions, to a coworker of a different sex, yet I was paid less. The pay difference was not explained by seniority, merit, or any factor other than sex. I believe I was underpaid in violation of the Equal Pay Act and Title VII.
Teaching point
Well pleaded because it tracks the Equal Pay Act elements: equal work measured by skill, effort, responsibility, and working conditions, a pay disparity, and the absence of a lawful non-sex explanation.