## Facts

- Two nurses’ associations and individual Illinois state employees in predominantly female job classifications brought a putative class action against Illinois and related officials.
- Plaintiffs alleged Illinois paid employees in predominantly male job classifications higher wages than employees in predominantly female classifications.
- Plaintiffs alleged the wage differentials were not justified by differences in the relative value of the jobs and were maintained intentionally because of sex.
- The complaint asserted violations of Title VII and the Fourteenth Amendment’s Equal Protection Clause.
- The pleading included general allegations of intentional discrimination and detailed comparisons, supported by an attached study commonly associated with “comparable worth” analysis.
- The district court dismissed under Rule 12(b)(6), characterizing the case as an impermissible “comparable worth” claim.

## Issues

1. Whether the complaint, read as a whole, plausibly alleged intentional sex-based wage discrimination under Title VII and the Equal Protection Clause, rather than only a nonactionable demand for pay parity based on “comparable worth.”
2. Whether dismissal under Rule 12(b)(6) was proper where at least one reasonable reading of an ambiguous complaint stated a legally cognizable claim.

## Decision

- The Seventh Circuit reversed the Rule 12(b)(6) dismissal and remanded.
- The court held that a freestanding “comparable worth” theory is not itself a cause of action under federal antidiscrimination law.
- The court concluded, however, that the complaint could fairly be read to allege intentional sex discrimination in setting or maintaining wage levels, which is actionable.
- Because the district court did not reach the State’s alternative request for summary judgment and there had been no discovery, the appellate court limited its review to pleading sufficiency.

## Legal Principles

- A court may not dismiss under Rule 12(b)(6) when an ambiguous complaint has a reasonable interpretation that states a claim for relief.
- Title VII and equal protection prohibit intentional wage discrimination because of sex; they do not impose a general requirement that employers set wages according to job-evaluation measures of “comparable worth.”
- References to job-comparison studies and examples associated with “comparable worth” do not defeat a complaint that also alleges intentional discrimination; such material may function as evidentiary support rather than as the sole legal theory.
- If a complaint is unclear, the appropriate response is clarification (including a more definite statement) and fact development through discovery, not dismissal where a viable claim is discernible.

## Conclusion

The Seventh Circuit held that, although federal law does not recognize a standalone comparable-worth entitlement, a complaint that can reasonably be read to allege intentional sex-based wage discrimination states a claim and should not be dismissed at the pleading stage.


Am. Nurses’ Ass’n v. Illinois, 783 F.2d 716 (7th Cir. 1986)