Celesq® Attorneys Ed Center

Changing Legal Standards for Bringing Gender-Based Pay Disparity Claims in the Second Circuit

Program Number: 30106

Program Date: 05/19/2020


This program discusses the standard for bringing gender-based pay disparity claims under the Equal Pay Act and Title VII. The program will provide basic background information including a review of the purposes of, the similarities and differences between and the remedies available under both laws. We will then review prior New York federal district and appellate court rulings discussing the legal standards for making a prima facie case of discrimination under the Equal Pay Act and Title VII. Specifically, we will discuss how prior to a Second Circuit decision in late 2019 clarified the law, New York federal courts were conflating the legal standards for bringing a Title VII claim with an Equal Pay Act claim. Further, we will discuss how by conflating these standards, courts left certain claimants with otherwise legitimate gender-based pay disparity claims with no legal remedy. Finally, we will review the Second Circuit’s December 2019 decision in Lenzi v. Systemax, 944 F.3d 97 (2d Cir. 2019), which clarified the standard for bringing a Title VII gender-based pay discrimination claim, likely making it easier for a plaintiff to bring such claims.

$95.00Online Audio Add to Cart

Available in states

California, Colorado Eligible, Florida, Georgia, New Jersey Eligible, New York, Texas Self Study

Credit Information

50 minute credit hour - 1.0 General CLE credit, based on a 50-minute credit hour, including 1.0 credit Diversity, Inclusion and Elimination of Bias
60 minute credit hour - 1.0 General CLE credit, based on a 60-minute credit hour, including 1.0 credit Diversity, Inclusion and Elimination of Bias

State Program Numbers


Christopher R. Dyess, Esq.

Schlam Stone & Dolan LLP

Chris Dyess joined the firm as an associate in 2020. While at the firm, Mr. Dyess’ practice focuses on representing individuals and business of all sizes in commercial disputes in federal and state courts as well as arbitrations and mediations. In addition to Mr. Dyess’ robust complex commercial litigation practice, he also represents and counsels businesses in employment law matters.

Prior to joining the firm, Mr. Dyess was an employment counselor and litigator at Weil, Gotshal & Manges LLP’s New York office. While there, Mr. Dyess was a key member of the firm’s internationally recognized Employment Litigation Practice Group. Mr. Dyess began his legal career as an attorney in the Complex Commercial Litigation practice group at Latham & Watkins LLP’s Chicago office.

Mr. Dyess has represented some of the largest companies in the United States in high-stakes “bet the company” cases. Mr. Dyess has a broad array of litigation experience encompassing all areas of pre-trial litigation. Mr. Dyess has extensive experience counseling clients through all phases of the litigation process including written and document discovery, motion practice, litigation strategy, depositions and working with experts to develop reports and prepare for testimony.

While Mr. Dyess enjoys the art of litigating, his business experience working for a large commercial banking institution prior to law school gives him the perspective necessary to always consider his clients’ business needs first. Mr. Dyess understands that often the best outcome for a client does not involve litigating matters in court. Mr. Dyess strives to counsel his clients long before a formal dispute arises to provide strategic advice that serves his clients’ business needs and long-term strategic objectives.

Mr. Dyess is also a board member of the Northwestern Pritzker School of Law New York City Alumni Association. Prior to his career in business and as an attorney, Mr. Dyess was a professional musician in New Orleans, LA where he grew up. Mr. Dyess continues to play music in New York City.