## Facts

- A public school district paid female coaches of girls’ teams less than male coaches of boys’ teams in comparable sports.
- The Equal Employment Opportunity Commission sued under the Equal Pay Act (EPA); two female coaches intervened and added Title VII and 42 U.S.C. § 1983 claims.
- The district court found the coaching work at issue was substantially equal in skill, effort, and responsibility under similar working conditions.
- The district court held the district violated the EPA and that the violation was willful, applying a three-year limitations period.
- Despite willfulness, the district court denied liquidated (double) damages based on a finding of good faith and reasonable grounds.
- The district court rejected the intervenors’ Title VII disparate-treatment and § 1983 equal-protection claims for lack of intentional discrimination, but found Title VII disparate impact and granted injunctive relief later resolved by consent decree.
- The district court awarded attorneys’ fees to the intervenors; the school district appealed EPA liability, willfulness, and fees, and the plaintiffs cross-appealed liquidated damages and the dismissal of intentional-discrimination claims.

## Issues

1. Whether the district violated the EPA by paying female coaches less than male coaches for substantially equal coaching work, and whether the district proved an EPA affirmative defense, including a “factor other than sex.”
2. Whether the EPA violation was willful for purposes of the three-year limitations period under 29 U.S.C. § 255(a).
3. Whether liquidated damages were required under 29 U.S.C. §§ 216(b), 260, or could be denied based on good faith and reasonable grounds.
4. Whether the evidence required findings of intentional sex discrimination sufficient to support Title VII disparate-treatment and § 1983 equal-protection liability.
5. Whether the attorneys’ fee award was reasonable given the intervenors’ degree of success.

## Decision

- Affirmed EPA liability; the coaching jobs were substantially equal and the district failed to prove a valid “factor other than sex” justification.
- Affirmed the finding of willfulness and the resulting three-year limitations period.
- Reversed the denial of liquidated damages and remanded with instructions to award liquidated (double) damages.
- Affirmed dismissal of the Title VII disparate-treatment and § 1983 claims for lack of intentional discrimination.
- Largely affirmed the attorneys’ fee award, with limited refinement to account for partial success and overlapping claims.

## Legal Principles

- Under the EPA, once a plaintiff shows a wage differential for substantially equal work, the employer bears the burden to prove a statutory defense, including that the differential is based on a bona fide factor other than sex.
- The “factor other than sex” defense cannot rest on sex-linked valuations (e.g., paying more because the team coached is boys’ rather than girls’) when the work itself is substantially the same.
- An EPA violation is willful for limitations purposes when the employer knew, or showed reckless disregard for whether, its pay practice was unlawful.
- Liquidated damages are the default remedy under the EPA/FLSA scheme; the employer must prove both subjective good faith and objectively reasonable grounds to avoid doubling, and a willfulness finding strongly conflicts with that showing.
- Title VII disparate-treatment and § 1983 equal-protection claims require proof of intentional discrimination; disparate impact or an EPA violation alone does not establish intent.
- Attorneys’ fees should be reasonable in relation to results obtained and may account for overlap between successful and unsuccessful claims.

## Conclusion

The Seventh Circuit held that paying female coaches less than male coaches for substantially equal coaching work violated the Equal Pay Act and was willful, required liquidated damages because the district did not prove good faith and reasonable grounds, and affirmed the rejection of intentional-discrimination claims while largely sustaining the fee award.


Equal Emp. Opportunity Comm'n v. Madison Cmty. Unit Sch. Dist. No. 12, 818 F.2d 577 (7th Cir. 1987)