Marinello v. CENTRAL BUCKS SCHOOL DISTRICT

District Court, E.D. Pennsylvania·Decided July 15, 2025·No. 2:21-cv-02587·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

REBECCA CARTEE-HARING

v. CIVIL ACTION NO. 20-1995 CENTRAL BUCKS SCHOOL DISTRICT, Defendant. DAWN MARINELLO, on behalf of herself and similarly situated plaintiffs, Plaintiff, CIVIL ACTION NO. 21-2587 v.

CENTRAL BUCKS SCHOOL DISTRICT, Defendant.

MEMORANDUM RE: PARTIES’ POST-TRIAL MOTIONS Baylson, J. July 15, 2025 After nearly five years of extensive motion practice, contentious discovery, evidentiary hearings, and a mistrial, these two consolidated cases have finally attained a judgment. Following a second trial, a unanimous jury found that the Central Bucks School District (“Central Bucks” or “Defendant”) violated the Equal Pay Act (“EPA”) by paying female teachers Dawn Marinello and Rebecca Cartee-Haring (“Plaintiffs”) lower wages than a male teacher performing substantially equal work, and that Defendant did not prove an affirmative defense. The jury awarded Plaintiffs back-pay damages in amounts lower than what Plaintiffs were seeking. The parties have each filed Rule 50 and Rule 59 post-trial motions: Plaintiffs’ Motion for Judgment as a Matter of Law and/or to Modify or Amend Judgment (ECF 469) and Defendant’s Motion for Judgment Notwithstanding the Verdict or in the Alternative, for a New Trial (ECF 470).1 For the following reasons, the Court will GRANT IN PART and DENY IN PART Plaintiffs’ Motion, and will DENY Defendant’s Motion. I. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND As the parties are well versed in these lengthy proceedings, the Court will limit its discussion to those facts and procedural history relevant to these Motions.

A. The First Trial Plaintiffs are both female English teachers in the Central Bucks School District who alleged that they were compensated less than male teachers performing substantially equal work.2 Rebecca Cartee-Haring filed her Complaint on April 22, 2020, and Dawn Marinello followed with her Complaint, on behalf of herself and a collective of those similarly situated, on June 8, 2021. Both Plaintiffs based their claims exclusively in the federal Equal Pay Act (29 U.S.C. § 206(d)(1)).3 Case No. 21-2587, ECF 81; Case No. 20-1995, ECF 26. The Court subsequently consolidated the two cases on November 23, 2021 for all purposes except trial, ECF 17, and for trial on February 27, 2025, ECF 363. Following a hearing, the Court “certified” a collective action on August 24, 2022, ECF 54-

55, and a five-day trial ensued in July 2024 with over 300 opt-in Plaintiffs. The jury was unable to reach a verdict, and on July 31, 2024, the Court declared a mistrial. ECF 305. The Court refers

1 Consistent with prior opinions, the Court refers to the docket entries in Marinello v. Central Bucks School District, No. 21-2587, unless otherwise indicated.

Defendant also filed a Motion to Alter Judgment (ECF 472) that is addressed in the accompanying Order. Plaintiffs’ Petition for Attorneys’ Fees and Costs (ECF 471) will be addressed separately.

2 Plaintiff Rebecca Cartee-Haring has since left the District.

3 Though Plaintiff Rebecca Cartee-Haring also alleged violations of Title VII, the Age Discrimination in Employment Act, and the Americans with Disabilities Act in her Third Amended Complaint, those allegations concern a separate issue of Cartee-Haring’s alleged termination as lacrosse coach and are unrelated to the core disputes in this trial regarding discriminatory compensation. On June 11, 2024, the Court dismissed those claims related to lacrosse coaching at summary judgment and only permitted the Equal Pay Act claim to continue. ECF 167. to its prior memoranda at ECF 393, 395 and to its memorandum in the related case Jakubik v. Gibson, 25-33, ECF 8, for a comprehensive review of the prior proceedings. B. The Second Trial After the first trial ended with a hung jury, the Court set parameters for how the second trial would proceed within the legal bounds of the Equal Pay Act.

1. The Court sua sponte decertified the collective action after hearing copious testimony at the first trial and reviewing the voluminous evidentiary record, finding that further fact development showed Plaintiffs were not similarly situated. ECF 313; see also Jakubik, ECF 8. The Court allowed the dismissed Plaintiffs to initiate their own individual lawsuits. ECF 313. 2. The Court Ordered Plaintiffs to designate two male comparators who were specific teachers of specific academic subjects whom Plaintiffs alleged were paid more, consistent with what the Equal Pay Act requires to prove a violation. ECF 326, 331. At the first trial, Plaintiffs’ Counsel had proceeded on an unfounded theory that all “teachers”—including any school professional employee, whether paid more or less—were comparators. 3. The Court required the parties to calculate the maximum potential damages in strict

accordance with the Third Circuit’s Model Jury Instructions assuming the two Plaintiffs succeeded in proving liability based on one or two male comparators. ECF 359. Plaintiffs calculated back- pay damages for Ms. Cartee-Haring extending back to 2007 and for Ms. Marinello back to 2016, and Defendant refused to calculate damages at all. ECF 360, 361. 4. The Court precluded Defendant from presenting evidence to rebut Plaintiffs’ damages evidence due to Defendant’s refusal to calculate maximum potential damages in accordance with the Court’s prior Orders and Third Circuit precedent. ECF 429, ¶ 2. 5. At the first trial, Plaintiffs’ Counsel attempted to prove an EPA violation based on a disparate treatment theory – that male teachers were “credited” for more prior teaching experience than the female Plaintiffs for purposes of determining their placement on the District’s Salary Scales. Prior to the second trial, the Court ruled that while it would permit evidence that Plaintiffs were improperly placed on the Salary Scales compared to certain male teachers as factual background, disparate placement on the District’s Salary Scales and disparate treatment of

Plaintiffs’ prior years of teaching experience were not valid theories of liability under the Equal Pay Act, which strictly concerns the differences in compensation; those theories are more appropriate in a Title VII discrimination case. Id., ¶ 3; ECF 436. The second trial began on May 5, 2025. Plaintiffs called seven witnesses: • Christina Lang, a principal at the Unami Middle School in the Central Bucks School District from 2013 to 2018 and formerly a middle school teacher. Tr. (5/5/2025), ECF 459, at 30:17–31:1. • Kevin McDermott, a social studies teacher who worked at Central Bucks from 1993 to 2024. Tr. (5/5/2025), ECF 459, at 64:12–15.

• John Donnelly (by video deposition), a high school social studies teacher and football coach at Central Bucks from 2010 to the present, and one of Plaintiffs’ two designated comparators. Tr. (5/5/2025), ECF 459, at 80:10–82:4. • Rebecca Cartee-Haring, a high school English teacher at Central Bucks from 2007 to 2024 and one of the two Plaintiffs. Tr. (5/5/2025), ECF 459, at 118:7–22. • Malcolm Mosley, a high school social studies teacher at Central Bucks for 17 years, and one of Plaintiffs’ two designated comparators. Tr. (5/6/2025), ECF 460, at 56:23–57:7. • Dr. Abram Lucabaugh, a former principal, assistant superintendent, and superintendent

at Central Bucks for 20 years. Tr. (5/6/2025), ECF 460, at 91:14–92:4. • Dawn Marinello, a middle school English teacher at Central Bucks from the 2016–2017 school year to the present and one of the two Plaintiffs. Tr. (5/6/2025), ECF 460, at 107:7– 108:15. Defendant called two witnesses: • Dr. Robert Laws (by video deposition), superintendent at Central Bucks from 1992 to

2012. Tr. (5/6/2025), ECF 460, at 143:19–20.

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