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Equal Pay-Sex Discrimination

By: WISCONSIN LAW JOURNAL STAFF//May 6, 2024//

Equal Pay-Sex Discrimination

By: WISCONSIN LAW JOURNAL STAFF//May 6, 2024//

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7th Circuit Court of Appeals

Case Name: Monica Rongere v. City of Rockford, Illinois

Case No.: 23-1761

Officials: Rovner, Brennan, and Kirsch, Circuit Judges.

Focus: Equal Pay-Sex Discrimination

Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, filed a lawsuit against the city following her termination from employment, alleging that she had been subjected to overwork and unequal pay compared to her male counterparts, attributing her termination to her vocalization of this inequality. She brought forth claims under various statutes including the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, citing unequal pay, sex discrimination, hostile work environment, and retaliation.

The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, subsequently relinquishing jurisdiction over the remaining state-law claims. Rongere challenged this decision on appeal.

The Seventh Circuit upheld the district court’s ruling. The court determined that Rongere had not adequately identified suitable comparators for her equal pay and sex discrimination claims, failed to demonstrate engagement in protected activity based on an objectively reasonable belief for her retaliation claim, lacked substantial evidence of a hostile work environment, and did not establish how the district court had abused its discretion in ceding jurisdiction over the remaining claims. Additionally, the court concluded that Rongere did not possess an objectively reasonable belief that the City discriminated in pay between male and female employees for similar work, a crucial requirement for her retaliation claims.

Affirmed.

Decided 04/30/24

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