The United States Court of Appeals for the Federal Circuit affirmed summary judgment to the United States on an Equal Pay Act claim brought by a female supervisory program manager at the Department of Homeland Security who alleged she was paid less than a male colleague for overtime work, finding that she failed to establish a prima facie case because the positions didn’t require equal skill, effort, responsibility, and weren’t performed under similar working conditions, and the government successfully raised an affirmative defense that the pay differential was based on factors other than sex.
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