Spaulding v. University of Washington

The University of Washington (defendant) nursing school employed Margaret Spaulding, Ruth Fine, and others (nursing faculty) (plaintiffs) as faculty members. Fine was also a university hospital administrator. The university’s 16 schools independently appointed faculty and determined salaries. In 1972, nursing faculty members filed a sex-based wage-discrimination petition with the university. The university studied its salaries, and the budget office allocated an additional 2 percent increase to the nursing school to align it with the university’s average salary deficit vis-à-vis other universities. Some nursing faculty perceived a discriminatory attitude. The university explained that salaries varied across schools because different academic disciplines merited different salaries based on training or demand for that discipline. The nursing faculty brought sex-based wage discrimination claims under § 1983, the Equal Pay Act (EPA), and Title VII of the Civil Rights Act of 1964 (Title VII). The nursing faculty argued their jobs were like comparator faculty members in other professional schools because both jobs required teaching, research, publication, committee work, student advising, and community service. A magistrate found the day-to-day responsibilities, skill, and effort of the comparators were different, and the nursing faculty’s statistics assumed, rather than proved, that the comparator jobs were substantially equal. As to Fine specifically, her job was not substantially equal to two male hospital administrators, because they held more responsibilities. The district court dismissed the claims. The nursing faculty appealed.