## Facts

- Kyriaki Cleo Kyriazi, a female engineer at Western Electric’s Kearny, New Jersey plant, sued under Title VII on behalf of herself and a class of women employees, former employees, and certain applicants.
- The action alleged plant-wide sex discrimination affecting hiring, job assignment, promotion, training, layoffs, and compensation, including segregation into lower-paid “women’s jobs.”
- The court bifurcated the case into a liability phase (“Stage I”) and a remedies/damages phase (“Stage II”).
- In Stage I, the court found Western had systematically discriminated against women and found Kyriazi was underpaid, denied promotions, harassed, and discharged because of sex and in retaliation for complaints.
- Stage II addressed the scope of the remedial class, the method for determining and distributing monetary relief (especially back pay), and the content of injunctive and structural relief.

## Issues

1. Which women connected to the Kearny plant were eligible for class relief based on the established pattern or practice of sex discrimination?
2. How should back pay and related monetary relief be calculated and distributed where discrimination was proven largely through statistical disparities?
3. To what extent could the court use formula and statistical approaches to approximate individual awards rather than requiring individualized proof of exact loss by each claimant?
4. What injunctive and structural measures were necessary to eliminate discriminatory practices and prevent recurrence?

## Decision

- The court implemented broad class relief for women affected by Western’s discriminatory practices at the Kearny plant.
- The court awarded classwide back pay and set procedures and rules for determining individual eligibility and amounts.
- The court approved use of statistical and formula-based methods to approximate individual back pay where systemic discrimination made precise reconstruction impracticable.
- The court ordered extensive injunctive and structural reforms to Western’s hiring, job assignment, promotion, evaluation, training access, and compliance reporting.
- The court awarded individualized relief to Kyriazi consistent with the established findings of sex discrimination and retaliation.

## Legal Principles

- Title VII authorizes broad equitable remedies, including classwide monetary relief and structural injunctions, where discrimination stems from entrenched employment practices.
- When a pattern or practice of discrimination is proven, courts may rely on reasonable statistical inferences and formula methods to estimate back pay and need not require each claimant to prove exact damages with precision.
- Remedial procedures may include standardized claim submissions and hearings as needed, while avoiding a requirement that victims reconstruct a hypothetical nondiscriminatory career path in detail.
- Uncertainty in calculating back pay attributable to proven discrimination may be resolved against the discriminating employer rather than against affected employees.
- Effective relief for systemic discrimination may require changes to selection, classification, advancement, and recordkeeping systems, along with monitoring and reporting obligations.

## Conclusion

The court, having already found systemic sex discrimination at Western Electric’s Kearny plant, fashioned classwide monetary and injunctive relief by approving statistical methods to approximate back pay, setting structured claim procedures, and ordering broad reforms to eradicate discriminatory practices and prevent recurrence under Title VII.


Kyriazi v. W. Elec. Co., 465 F. Supp. 1141 (D.N.J. 1979)