Judge Lara Montecalvo, nominated by President Biden to the First Circuit court of appeals, cast the deciding vote in a 2-1 ruling upholding a district court decision that a hospital corporation had to pay damages for violating the Maine Equal Pay Law (MEPL) by paying male psychologists more than a female psychologist for comparable work. The January 2024 decision was in Mundell v Acadia Hospital Corp.

 

What happened in this case?

 Clare Mundell worked for more than two years as a licensed clinical psychologist at Acadia Hospital in Maine. She learned that Acadia paid her at “half the rate earned by her male colleagues for comparable work.” After exhausting administrative remedies, she filed suit in federal court under both federal and state law that required equal pay for men and women for equal work.

During extensive discovery, Acadia admitted that the disparity existed for comparable work, and that it was “not due to an established seniority system, merit pay system, or shift differences.” Based on these facts, Mundell moved for summary judgement on her MEPL claims. Acadia claimed that Mundell was required to prove intent to discriminate, and that the disparities were caused by “market factors” related to the rural nature of much of the state.

The district court rejected Acadia’s claims and entered summary judgment in Mundell’s favor on her MEPL claims, requiring the hospital to pay her damages under the law. Acadia appealed to the First Circuit.

 

How Did Judge Montecalvo and the First Circuit Rule and Why is it Important?

Judge Montecalvo cast the deciding vote in a 2-1 ruling that upheld the district court decision in favor of Mundell. In an extensive 54 page opinion, the majority explained that the district court was correct in rejecting the hopital’s arguments, which were repeated on appeal.

The majority carefully analyzed the language and history of the Maine statute, other comparable laws, and the relevant precedents. It concluded that the Maine law “unambiguously imposes liability” on employers for “pay differences between male and female employees for comparable work in comparable jobs without regard to the employer’s intent.” It also agreed with the district court and Mundell that the statute “allows as defenses only the three” specified in the statute, which the parties had agreed did not apply in this case.

The deciding vote of Judge Montecalvo was obviously important to ensuring that Clare Mundell would receive justice and full compensation for Acadia’s violation of the Maine equal pay law. It also stands as an important precedent in other cases involving the Maine statute, as well as other equal pay laws with comparable language. In addition, the ruling is an example of the importance of promptly confirming fair-minded Biden nominees like Judge Montecalvo to our federal courts.