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ARTICLE · 29 NOVEMBER 2022

Equal Pay Act Claim Should Not Have Been Dismissed

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Joyce Allen worked at Staples as a field sales director reporting to area sales vice president Bruce Trahey; FSD Charles R. Narlock also reported to Trahey.

United StatesEmployment and HR
Anthony Oncidi
Anthony Oncidi
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Allen v. Staples, Inc., 84 Cal. App. 5th 188 (2022)

Joyce Allen worked at Staples as a field sales director (FSD) reporting to area sales vice president Bruce Trahey; FSD Charles R. Narlock also reported to Trahey. As part of a corporate reorganization in February 2019, Trahey informed Allen and several other FSDs of his decision to eliminate their positions and terminate their employment. In her lawsuit, Allen alleged violation of the Equal Pay Act (EPA); gender discrimination and sexual harassment under the Fair Employment and Housing Act (FEHA); failure to prevent discrimination and harassment under FEHA; retaliation and wrongful termination in violation of public policy. The trial court granted defendants' motion for summary judgment and, in the alternative, summary adjudication of each cause of action. The Court of Appeal affirmed dismissal of all claims except Allen's EPA claim, including her claim for punitive damages.

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