## Facts

- The City of Los Angeles Department of Water and Power (DWP) operated a pension plan for its employees.
- The plan required female employees to contribute approximately 14.84% more than male employees to receive the same monthly retirement benefits.
- DWP justified the differential using mortality tables and its own experience indicating women, on average, live longer than men, increasing the expected cost of paying benefits.
- The higher contributions were collected through payroll deductions, reducing women’s take-home pay compared with similarly situated men.
- Marie Manhart and a certified class of present or former female employees sued under Title VII, alleging sex discrimination under § 703(a)(1).
- While the case was pending, DWP amended the plan to eliminate sex-based distinctions effective January 1, 1975, after state law barred such differentials.
- The district court held the plan unlawful and ordered refunds of women’s excess contributions made before the amendment; the Ninth Circuit affirmed.

## Issues

1. Whether requiring women to make higher pension contributions than men, based on actuarial longevity data, is discrimination “because of” sex under Title VII § 703(a)(1).
2. Whether Title VII permits retroactive monetary relief requiring refunds of the excess contributions paid before the plan was amended.

## Decision

- The Supreme Court held that the sex-based contribution differential violated Title VII § 703(a)(1).
- The Court reasoned that Title VII protects individuals and forbids treating an employee differently in a way that would not occur but for the employee’s sex, even if the employer relies on accurate group statistics.
- The Court rejected an argument that employee benefit plans should be subject to a different, more permissive discrimination standard.
- The Court vacated the lower courts’ award of broad retroactive refunds and remanded for reconsideration of appropriate relief, citing reliance interests and potential disruption to pension financing.

## Legal Principles

- Title VII prohibits explicit sex classifications in employee compensation terms, including required pension contributions, when similarly situated employees receive equal benefits.
- Statistical generalizations about groups (such as average longevity differences) do not justify imposing unequal burdens on individuals based on sex.
- A purported justification framed as a neutral factor is not a defense where, in operation, sex accounts for the differential treatment.
- Remedies in systemic benefits cases may be limited where employers reasonably relied on prior practice and where full retroactive monetary relief would cause substantial financial disruption; liability and remedy are analytically distinct.

## Conclusion

The Court ruled that a pension plan violates Title VII when it requires women to contribute more than men for the same retirement benefits based on sex-linked actuarial assumptions, but it restricted retroactive monetary relief by vacating the blanket refund order and remanding for a more limited remedy determination.


City of Los Angeles Dep't of Water & Power v. Manhart, 435 U.S. 702 (1978)