Wood v. City of San Diego

Janet Wood (plaintiff), an unmarried female employee of the City of San Diego (the city) (defendant), was enrolled in a pension plan administered by the city. Under the city’s pension plan, retiring employees chose how to allocate pension and survivor benefits upon retirement. One option was called the surviving-spouse benefit. If a married retiree chose the surviving-spouse benefit, the retiree received the full monthly pension until the retiree’s death, and the retiree’s surviving spouse or domestic partner received half of the monthly allowance. If an unmarried retiree chose the surviving-spouse benefit, the retiree would choose between receiving a lump-sum reimbursement of the survivor contributions or applying the survivor contributions to the pension. Married retirees, on average, received higher benefit amounts than unmarried retirees who chose the surviving-spouse benefit. Upon retirement, Wood chose the surviving-spouse benefit and elected to have the survivor contributions go towards the pension. Wood filed a class action against the city, claiming economic damages resulting from the city’s alleged disparate treatment of single female retirees. Wood also claimed that the pension plan had an unlawful disparate impact on female retirees because male retirees were more likely to be married than female retirees. Wood’s disparate-treatment and disparate-impact claims were brought under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination on the basis of a protected trait such as sex. The city motioned to dismiss both claims. The city argued that Wood failed to state a viable disparate-treatment claim because Wood did not allege any discriminatory intent or motive. The city also argued that the surviving-spouse benefit was based on seniority and had no unlawful disparate impact. The district court partially granted the city’s motion, dismissing the disparate-treatment claim but not the disparate-impact claim. Thereafter, upon the city’s motion for summary judgment, the district court dismissed the disparate-impact claim. Wood appealed.