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Keywords

contractbreach of contractappealsummary judgmentdiscriminationwrongful terminationcontractual obligationgood faithexpress contract
contractbreach of contractdefendantmotionsummary judgmentdiscriminationmotion for summary judgment

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Stanley v. University of Southern California, 178 F.3d 1069, 79 Fair Empl.Prac.Cas. (BNA) 1616, 76 Empl. Prac. Dec. P 46,014, 138 Lab.Cas. P 33,881, 44 Fed.R.Serv.3d 311, 135 Ed. Law Rep. 917, 99 Cal. Daily Op. Serv. 4192, 1999 Daily Journal D.A.R. 5278

Facts

Marianne Stanley, the former head coach of the women's basketball team at the University of Southern California (USC), sued the university and its athletic director, Michael Garrett, alleging violations of the Equal Pay Act and breach of her employment contract. Stanley claimed that she was entitled to a salary equal to that of the men's basketball coach, George Raveling, but the university argued that the pay differential was based on Raveling's significantly greater experience and qualifications. After a series of contract negotiations, Stanley's contract expired, and she was unable to secure a new agreement that met her salary demands. The district court granted summary judgment in favor of USC, leading to Stanley's appeal.

Stanley contends that on that date she entered into a contract for a salary equivalent to that of George Raveling, the USC men's basketball coach. It is undisputed that Garrett expressly stated that USC could not pay her that salary, but that he would make her a formal offer in writing shortly after that meeting.

Issue

Did the university violate the Equal Pay Act, Title IX, or any other laws in its treatment of Stanley, and was there a breach of contract?

Did the university violate the Equal Pay Act, Title IX, or any other laws in its treatment of Stanley, and was there a breach of contract?

Rule

Under the Equal Pay Act, an employee must establish a prima facie case of discrimination by showing that employees of the opposite sex were paid different wages for equal work. The employer can defend against this claim by demonstrating that the pay differential is based on a factor other than sex. Additionally, under California law, a breach of contract claim requires the existence of a valid contract, and an implied covenant of good faith and fair dealing cannot exist without a valid contract.

Analysis

The court found that the university's pay differential was justified based on Raveling's superior experience and qualifications, which constituted a factor other than sex. Stanley failed to demonstrate that the differences in pay were pretextual or that she and Raveling had comparable qualifications. Furthermore, the court determined that no express contract was formed regarding salary equalization, and the written contract's terms precluded any modifications without written consent. Thus, the university did not breach any contractual obligations.

Because university based its pay differential between male and female head basketball coaches on male coach's more extensive experience, university did not violate Title IX's prohibition against discrimination in educational programs receiving federal assistance, California Fair Employment and Housing Act (FEHA), or California Constitution's prohibition against disqualifying person from entering employment because of sex.

Conclusion

The court affirmed the district court's summary judgment in favor of the university, concluding that there was no violation of the Equal Pay Act or any other laws, and that Stanley's claims of breach of contract were unfounded.

Accordingly, we affirm the district court's decision to grant the defendants' motion for summary judgment on the Equal Pay Act claim.

Who won?

The University of Southern California prevailed in this case as the court found that the pay differential between the men's and women's basketball coaches was based on legitimate factors other than sex, specifically the greater experience and qualifications of the men's coach. The court also ruled that Stanley failed to establish a valid contract for equal pay and that her claims of discrimination and wrongful termination were without merit.

The University of Southern California prevailed in this case as the court found that the pay differential between the men's and women's basketball coaches was based on legitimate factors other than sex, specifically the greater experience and qualifications of the men's coach.

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