Wilmuth v. Amazon.com Inc

CourtDistrict Court, W.D. Washington
DecidedDecember 12, 2024
Docket2:23-cv-01774
StatusUnknown

This text of Wilmuth v. Amazon.com Inc (Wilmuth v. Amazon.com Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilmuth v. Amazon.com Inc, (W.D. Wash. 2024).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 CAROLINE WILMUTH, KATHERINE CASE NO. 2:23-cv-01774-JNW 8 SCHOMER, and ERIN COMBS, ORDER 9 Plaintiffs,

10 v.

11 AMAZON.COM INC.,

12 Defendant. 13 1. INTRODUCTION 14 Plaintiffs Caroline Wilmuth, Ph.D., Katherine Schomer, and Erin Combs sue 15 Defendant Amazon.com, Inc., alleging Amazon underpays and discriminates 16 against its female employees on a systemic scale. Citing Washington state and 17 federal employment laws, they bring class- and collective-action equal pay claims 18 for themselves and all similarly situated women. The also bring medical leave and 19 retaliation claims in their own names. 20 Amazon moves to dismiss or strike their claims, arguing that the proposed 21 class—all women who worked for Amazon in covered positions—is too broad and 22 unwieldly to sustain a class- or collective-action. Dkt. No. 34. Amazon also moves to 23 1 dismiss Dr. Wilmuth’s medical leave claim because, it argues, she fails to state a 2 claim. See id.; Fed. R. Civ. P. 12(f).

3 Having considered the briefing, the relevant record, and the governing law, 4 the Court finds oral argument unnecessary. The Court finds that Amazon’s motion 5 is premature, as it cannot say from the pleadings alone that Plaintiffs’ case is so 6 hopeless as a class or collective action that it must be dismissed at the start. 7 Plaintiffs’ allegations are best viewed through the prism of a class certification 8 motion after some opportunity for discovery. Accordingly, the Court DENIES

9 Amazon’s motion. 10 2. BACKGROUND1 11 Plaintiffs allege that Amazon “has systematically paid and continues to pay 12 female employees lower compensation than it has paid and continues to pay men 13 performing substantially equal or similar work” in violation of the federal Equal 14 Pay Act (EPA) and the Washington Equal Pay and Opportunities Act (EPOA). Dkt. 15 No. 33 ¶¶ 2, 19–22; see also Dkt. No. 33 at 3, 42–43.

16 To support their putative collective and class actions under the EPA and 17 EPOA, Plaintiffs provide detailed allegations explaining Amazon’s “unitary 18 operations, centralized decisionmaking, and uniform policies” for hiring, 19 promotions, job architecture, compensation, and evaluating performance. For 20 instance, Plaintiffs allege that “Amazon has a centralized HR department . . . which 21 1 On a motion to strike or dismiss for failure to state a claim, the Court must accept 22 all well-pleaded facts as true. Petrie v. Elec. Game Card, Inc., 761 F.3d 959, 966 (9th Cir. 2014). Thus, the Court recounts only the relevant facts alleged in the operative 23 complaint. 1 implements and dispenses all of Amazon’s personnel processes, including hiring, job 2 code and level assignments, promotion, and job evaluations, all of which impact

3 Amazon employees’ compensation.” Id. ¶ 34. They claim that Amazon workers 4 charged with conducting interviews follow rigid, uniform policies and effectively 5 have no discretion in the interview process. See id. at 11–13. Dr. Wilmuth states 6 that she “participated in over 75 interviews during her time at Amazon,” and each 7 functioned the same way. Id. ¶ 41. 8 The operative complaint also provides a detailed description of the “rigid job

9 architecture” that Amazon has implemented “to provide a framework for the 10 organization of its employees” around the world. Id. ¶ 43. It asserts: 11 Amazon uses a single set of job coding/ leveling structures throughout the company, across its locations, referred to as the “Leveling 12 Guidelines.” Whether an employee is in Seattle, New York, or Mumbai, the same job architecture/ Leveling Guidelines apply. 13 Id. Plaintiffs explain how Amazon uses uniform Job Levels, “Leveling Guidelines,” 14 “job families,” and “job codes” to systematically pay women less than men for 15 performing the same or substantially similar work. 16 According to the operative complaint, Amazon’s Job Levels work like this: 17 Amazon’s HR, in conjunction with Bar Raisers, assigns each corporate 18 salaried employee a job level from Level 4 (at the bottom) to Level 12 (at the top) based on a centralized rubric that defines the characteristic [sic] 19 of each level in connection with a given job code.

20 Amazon strictly controls job level assignments. Managers do not have discretion to change an employee’s job level. If a Manager wishes to 21 change the job level for a direct report within the first six months of employment, they must do so by appealing to the Bar Raiser who had 22 been on the employee’s hiring panel. Otherwise, a Manager has to wait 23 1 at least one year and then put the employee up for a promotion in order to raise their level. 2 Id. ¶¶ 44–45. 3 Along with Job Levels, Amazon applies “job codes” to its employees; these 4 codes indicate the “work to be performed and job qualifications” for a particular job. 5 Id. ¶ 47. Amazon organizes job codes by grouping similar, or related job codes into 6 the same “job family.” Id. As with Job Levels, “Amazon’s HR, in conjunction with 7 Bar Raisers, assign job codes based on Amazon’s Leveling Guidelines.” Id. ¶ 48. 8 “Managers do not have discretion to change an employee’s job code.” Id. ¶ 49. “If 9 managers believe a job code is incorrect, they must ask Amazon’s HR to conduct a 10 job code review.” Id. According to Plaintiffs, “Amazon maintains companywide 11 Leveling Guidelines governing both job levels and job codes,” which are uniformly 12 applied across the entire company. Id. ¶ 50. 13 Plaintiffs maintain that Amazon unlawfully pays women less than men with 14 the same job code. Plaintiffs also allege that within each job family (i.e., group of 15 related job codes), Amazon assigns the lower-paying job codes to women while 16 reserving the higher-paying codes for men. Illustrating the point, Schomer, a 17 researcher for Amazon, alleges that Amazon’s centralized HR assigned her the job 18 code for “Product Manager,” while coding her male research partner as a “Research 19 Scientist.” Id. ¶ 102. Schomer’s job code led Amazon to pay her less than her male 20 research partner, even though she was more qualified and had a higher Job Level 21 than him. Id. 22 23 1 Then, when Schomer switched to a different Amazon research team, Amazon 2 coded her as a “Senior Research Manager.” Id. ¶ 103. Again, Amazon coded

3 Schomer’s male counterpart as a “Research Scientist.” Id. ¶ 104. The maximum 4 salary for Schomer’s job code was around $367,000, “while the Research Scientist 5 job code has a minimum compensation of $570,000 and tops out at approximately 6 $900,000.” Id. ¶ 105. Schomer alleges that her job code resulted in Amazon paying 7 her male comparator approximately 150 percent of her salary. Id. ¶ 104. 8 Separate from their class and collective action claims, Plaintiffs also allege

9 that Amazon discriminated and retaliated against them individually for taking 10 medical leave and for raising concerns about unequal pay and treatment. See id. at 11 38–40. In Spring 2023, Dr. Wilmuth took about a month of protected FMLA medical 12 leave because of a decline in her physical and mental health, resulting from 13 Amazon’s discriminatory practices. Id. ¶ 177. Dr. Wilmuth alleges that when she 14 took leave, Amazon HR shared private information about her discrimination 15 complaints and “troubled situation” with her coworkers, which damaged her

16 professional reputation. Id. ¶ 179–80. Indeed, she claims that while she was on 17 leave, her coworkers made comments like, “If I was her, I wouldn’t come back from 18 leave.” Id. On October 23, 2023, Dr. Wilmuth submitted a claim to “EthicsPoint,” 19 regarding this problem. Id. ¶ 181. Amazon did not address the complaint. Id. 20 On November 20, 2023, Plaintiffs filed this lawsuit.

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Wilmuth v. Amazon.com Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilmuth-v-amazoncom-inc-wawd-2024.