Brewster v. Barnes

Summary

The Fourth Circuit held that a deputy sheriff was an employee under the Equal Pay Act and that her work was substantially equal to that of male correctional officers. It concluded that the defendants failed to prove that the pay disparity was based on a factor other than sex, while affirming the finding that they had not intentionally discriminated under Title VII. The court reversed the due-process judgment under 42 U.S.C. § 1983, held the Equal Pay Act claim timely, and remanded for modification of the judgment.

Holdings

1. Negligent conduct by a government official causing an unintended deprivation of property does not violate the Due Process Clause and therefore cannot support Brewster's § 1983 due-process claim.
2. Brewster was not a member of the sheriff's personal staff and therefore was an employee covered by the Equal Pay Act.
3. Brewster performed work substantially equal to that of the male correctional officers and established a prima facie violation of the Equal Pay Act.
4. The Compensation Board and Board of Supervisors failed to prove that the wage differential resulted from a seniority system, merit system, production-based system, or bona fide factor other than sex.
5. The defendants did not violate Title VII because Brewster failed to prove intentional discrimination based on sex.
6. The Equal Pay Act claim was timely because the defendants' refusal to provide Brewster the same seniority-based salary as male correctional officers constituted a continuing violation through the end of her employment.

Questions Presented

1. Whether negligent deprivation of a property interest supports a claim for deprivation of property without due process under 42 U.S.C. § 1983.
2. Whether Brewster was excluded from the Equal Pay Act's definition of employee because she was a member of the sheriff's personal staff.
3. Whether Brewster performed work substantially equal to that of male correctional officers.
4. Whether the defendants proved that the wage differential resulted from a statutory affirmative defense, including a factor other than sex.
5. Whether the defendants intentionally discriminated against Brewster because of sex in violation of Title VII.
6. Whether the Equal Pay Act claim was barred by the statute of limitations.
7. Whether the award of attorneys' fees and costs required modification after the appellate disposition.

Disposition

reversed_and_remanded