Sandra Selden v. Des Moines Area Community College

Summary

The court held that DMACC was entitled to directed verdicts on both Selden’s equal-pay and retaliation claims. The pay disparity was conclusively explained by gender-neutral factors, including a neutral seniority system, materially different labor-market conditions, and Tjaden’s greater relevant experience when hired. The retaliation claim lacked substantial evidence of causation because DMACC consistently screened out applicants who lacked the posted educational qualification and there was no evidence of retaliatory hostility.