Ryduchowski v. Port Authority of NY and NJ, 203 F. 3d 135 - Court of Appeals, 2nd Circuit 2000

Plaintiff-Appellant Danuta Ryduchowski ( Ryduchowski ) appeals from a judgment as a matter of law entered in the United States District Court for the Eastern District of New York (Gleeson, J.) setting aside a jury verdict in her favor on a claim asserted under the provisions of the Equal Pay Act of 1963 ( EPA ), 29 U.S.C. §§ 206(d), 215(a)(2). The court found no basis for the jury\u27s determination that Ryduchowski\u27s 137*137 former employer, defendant-appellee The Port Authority of New York and New Jersey ( Port Authority ), had not established a valid merit system defense. Three claims were tried to the jury: (1) a Title VII claim based on alleged unlawful failure to promote in 1995, see Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.; (2) an EPA claim based on Ryduchowski\u27s 1994 pay increase; and (3) an EPA claim with regard to Ryduchowski\u27s 1995 pay increase. The EPA claims alleged that Ryduchowski received impermissibly lower pay increases in 1994 and 1995 than a male counterpart. The jury\u27s verdict was favorable to the Port Authority with respect to all of Ryduchowski\u27s claims except the 1995 EPA claim, the jury having determined by a special finding that the Port Authority did not establish its affirmative defense of a valid merit system. Thereafter, the Port Authority moved for judgment as a matter of law. The district court granted the motion, finding that although Ryduchowski and her co-worker, Jeffrey Lopez ( Lopez ), were similarly situated, they had received justifiably different performance evaluations pursuant to a valid merit system, which explained the differences in their 1995 salary increases. For the reasons that follow, we reverse the judgment of the district court and reinstate the jury verdict. We remand to the district court so it may assess plaintiff\u27s damages