# Cora Aldrich v. Randolph Central School District and Cattaraugus County Civil Service Commission

> Court of Appeals for the Second Circuit · May 5, 1992 · 963 F.2d 520

URL: https://www.frixlaw.com/law-library/cases/9482909

## Case

- **Full name:** Cora ALDRICH, Plaintiff-Appellant, v. RANDOLPH CENTRAL SCHOOL DISTRICT and Cattaraugus County Civil Service Commission, Defendants-Appellees
- **Court:** Court of Appeals for the Second Circuit
- **Decided:** May 5, 1992
- **Citations:** 963 F.2d 520; 30 Wage & Hour Cas. (BNA) 1457; 58 Empl. Prac. Dec. (CCH) 41,477; 58 Fair Empl. Prac. Cas. (BNA) 1373; 1992 U.S. App. LEXIS 9833
- **Precedential status:** Published
- **Opinion:** Concurrence by Pratt
- **Judges:** Oakes, Newman, Pratt
- **Cited by:** 480 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9482909

## How later opinions describe it (automated extraction)

- explaining that the fourth affirmative defense imposes a “job-relatedness requirement” and that employers must prove that the pay differential is “rooted in legitimate business-related differences in work responsibilities and qualifications for the particular positions at issu…
- holding that factor other than sex that creates pay differential between men' and women performing the same job must be rooted in legitimate business-related differences in work responsibilities and qualifications for the particular positions at issue
- holding that an employer must prove that the "system resulting in differential pay is rooted in legitimate business-related differences in work responsibilities and qualifications”
- recognizing “that job classification systems may qualify under the factor-other than-sex defense only when they are based on legitimate business-related considerations”
- holding employer must prove that “system resulting in differential pay is rooted in legitimate business-related differences in work responsibilities and qualifications”

## Opinion text

GEORGE C. PRATT, Circuit Judge,
concurring.
I concur in all three holdings of Chief Judge Oakes’ opinion: (1) that the district court properly granted summary judgment for the school district on Aldrich’s Title VII claim of sex-based wage discrimination; (2) that summary judgment dismissing Ald-rich’s retaliation claim was proper; and (3) that there is a triable issue defeating summary judgment on Aldrich’s claim under the Equal Pay Act. I write only to focus a little more closely on the Equal Pay Act ruling.
As noted in the opinion, Aldrich’s claim under the Equal Pay Act is that, as a lower-paid cleaner, she was assigned and performed the same duties as the higher-paid, male, civil service-qualified custodians, and that under the Equal Pay Act this entitled her to recover the differential.
While the school district is entitled to raise the “any other factor other than sex” defense of reliance on the civil service classification system, it must, as the opinion points out, show that the examination-based system and the district’s reliance upon it is job-related and bona fide.
As correctly noted in the opinion, “Aid-rich raises a genuine factual issue on the question whether she performs the same work as the male custodians”, ante at 527; this determination requires reversal of the summary judgment. Much of the opinion, however, is taken up with a discussion of the need for the school district to go further than simply asserting its reliance upon the civil service examination and classification system. The opinion stresses the need for the school district to establish as a condition for its “any other factor other than sex” defense that this state-controlled job classification and hiring system is job-related. I have no quarrel with this concept, but am both perplexed at the need for stressing it in the context of this case, and concerned lest it distract the parties and the district court from the heart of this particular dispute.
Under the New York State civil service system, jobs are classified into various categories, examinations are periodically given for each of the classifications, and appointments may be made from any of the three highest-scoring available applicants. See N.Y.Civ.Serv.Law § 61 (McKinney Supp. 1992). Municipalities such as the Randolph Central School District are required by law to hire and promote from the civil service lists. See generally. N.Y.Civ.Serv.Law § 20 (McKinney Supp.1992). Moreover, the Civil Service Commission goes to great lengths to see that its examinations are job-related. See Cattaraugus County Civil Service Commission, Local Administration of the New York State Civil Service Law (March 1991). On request, it will analyze a particular position, as it did here, to see if it falls within the classification assigned to it by the governmental employer. It is thus almost unthinkable that on remand, after a reexamination of the civil service’s *530 custodian and cleaner classifications, the district court could possibly conclude that these classifications were not “job-related”.
As I view this case, the crux of Aldrich’s appeal is not the underlying validity or job-relatedness of the civil service examinations and hiring procedures, because those aspects of the system are not in dispute. Instead, the controversy focuses on the actual practices of the school district in assigning work to Aldrich, as a cleaner, and to her male co-employees, as custodians.
On the remand, when it applies the “any other factor other than sex” defense to the unique problems of this case, the district court must inevitably determine whether in assigning the work the school district actually followed the civil service classifications of “custodian” and “cleaner”. If it did not, and instead had Aldrich doing the same work as the higher-paid custodians, then the civil service classification system, as applied to Aldrich in this case, was not bona fide and job-related, and the district’s defense would fail.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9482909. Public record. Not legal advice.