Law 310

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Laffey v. Northwest Airlines 567 F.2d 429 (U.S. Court of Appeals, District of Columbia Circuit, 1976) Facts: NWA started international flights and created a new cabin-attendant position of “purser” and adopted a policy of only hiring men for the purser position. The only female purser was Mary P. Laffey, who bid for a purser vacancy after nine years of being a stewardess. NWA delayed acting on her application and began to administer new tests to purser applicants. NWA hired two male pursers without benefit of any tests. Laffey final became a purser, but was placed on the bottom rung of the purser-salary schedule and was paid less than male pursers with equivalent seniority and cabin attendant service. NWA also paid female stewardesses lower salaries and pensions than male pursers, provided female cabin attendants with less expensive and less desirable layover accommodations than male cabin attendants, and a uniform cleaning allowance was not granted to female attendants. Laffey filed a class action lawsuit against NWA, claiming the refusal to hire female as pursers violated Title VII and that the differential pay scale and allowances for male pursers and female attendants violated Title VII and the Equal Pay Act. Issue: Whether the jobs of purser and stewardess equivalent in terms of the skills, effort, responsibilities, and working conditions for the purpose of the Equal Pay Act. Holding: NWA had violated Title VII and the Equal Pay Act. The court made extensive findings comparing the work actually done by pursers and stewardess and held it to be essentially equal when considered as a whole. NWA had failed to show that the differences in pay and benefit allowances were justified under any of the four exceptions of the Equal Pay Act. Reasoning:

* Both pursers and stewardesses must check cabins before departure, greet and seat passengers, prepare for take-off, and provide in-flight food, beverage, and general services * The primary responsibility of any...
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