This Note examines the reasoning behind the several circuit courts' (Tenth, Ninth, Eighth, and Sixth) differing answers to the question of whether a violation of the Equal Pay Act will automatically lead to Title VII liability and the effect the different answers have on the allocation of the burden of proof under a Title VII claim. Finally, a critical analysis is done to determine which rule—the "equivalence" or "no equivalence"—is based upon better reasoning.
DaNay A. Kalkowski,
Does Liability under the Equal Pay Act Automatically Lead to Title VII Liability?—Fallon v. State of Illinois, 882 F.2d 1206 (7th Cir. 1989),
70 Neb. L. Rev.
Available at: http://digitalcommons.unl.edu/nlr/vol70/iss3/8