Am. Nurses' Ass'n v. State of Illinois

Facts: Nurses (female dominated profession at the time) in Illinois got paid less than comparable male-dominated counterparts.

Procedural History: District judge dismissed under FRCP 12(b)(6). Ground for the dismissal was that the complaint pleaded a comparable worth case and that a failure to pay employees in accordance with comparable worth does not violate federal antidiscrimination law.

Issue: What issue is the complaint complaining about- is it that the state failed to compensate based on comparable worth (non-actionable), or that the state deliberately and therefore unlawfully discriminated against females?

Holding: The complaint can't necessarily be found to not give a valid federal cause of action.

Reasons: Facts don't necessarily show that plaintiff is not entitled to relief. Plaintiffs are entitled to make additional efforts to probe a case of intentional discrimination.

Judgment: Reversed and remanded.