Brennan v. Victoria Bank & Trust Co.

Victoria Bank & Trust Company (the bank) (defendant) employed exchange tellers and note tellers within its note department. Marjorie Chanek began working for the bank in 1960. Chanek became an exchange teller in 1963 at a salary of $265 per month and left the position in 1965 with a monthly salary of $325. Carlton Speck began working at the bank in 1954 and assumed Chanek’s exchange-teller position in 1965 at a monthly salary of $410. The bank claimed Speck’s higher salary was based on his greater seniority as compared to Chanek. The bank maintained an official seniority and merit system by which raises were awarded based on standard longevity increases, with some consideration of merit assessed through annual evaluations. As for the note-teller group, the bank hired eight women and one man, Stephen Wallace, between 1968 and 1971. Wallace was hired with a salary of $325 per month and had no college or relevant employment experience. Other than one woman who also earned $325 per month, the remaining seven all earned between $280 and $300 despite the fact that most had some college and relevant experience. The individual salaries were purportedly based on various factors, including college and work experience, subjective personality assessments, and market forces. The secretary of labor (plaintiff) brought suit against the bank for violation of the Equal Pay Act of 1963. The district court found no violation with respect to either the exchange tellers or the note tellers, and the secretary of labor appealed.