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Griffin v. Michigan Department of Corrections
United States Court of Appeals for the Sixth Circuit
5 F.3d 186 (1993)
Constance Anderson (plaintiff) was a female employee at the Michigan Department of Corrections (department) (defendant). In 1982, the district court held that the department engaged in sex discrimination against Anderson in violation of Title VII of the Civil Rights Act of 1964 (Title VII). In a 1988 order, the district court granted Anderson a front-pay award. The award required that Anderson be compensated and promoted as though she had followed the career progression of a male department employee, Gerald Hofbauer. The district court did not determine whether the promotions Hofbauer received were promotions that would have been obtained by an average worker with Anderson’s qualifications. The department did not appeal the 1988 order at the time it was issued. In a 1991 order, the district court required that, based on Hofbauer’s career progression, Anderson be promoted to the Deputy Prison Warden XII position. The department appealed the 1991 order.
Rule of Law
Holding and Reasoning (Boggs, J.)
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