Edelman v. NYU Langone Health System
- Lewis Liman
- 1:21-cv-00502
- U.S. District Court · Southern District of New York
- 2
In Edelman v. NYU Langone Health System, Judge Schofield denied reconsideration of the ruling leaving Dr. Edelman’s Equal Pay Act claims for trial.
Dr. Sari Edelman and the defendants, including NYU Langone Health System. The defendants’ request to reconsider the earlier summary-judgment ruling was denied, and factual disputes concerning the Equal Pay Act claims remain for trial.
What happened
In Edelman v. NYU Langone Health System, the defendants asked the court to reconsider the part of an earlier order that denied summary judgment on Dr. Sari Edelman’s Equal Pay Act claims.
The defendants argued that certain facts about Dr. Edelman’s prior salary, NYU’s profitability assessment, productivity bonuses, and compensation based on work relative value units required a different result. The court said it had already considered these arguments and that factual disputes remained about whether gender bias affected compensation and whether permissible factors explained differences in productivity-adjusted pay.
The court denied the defendants’ motion for reconsideration and directed the clerk to close the motion. Judge Lorna G. Schofield stated that the remaining factual disputes must be resolved at trial.
The detailed version
- Edelman v. NYU Langone Health System · No. 1:21-cv-00502
- Lewis Liman
- Oct. 24, 2022
Background
The defendants moved for reconsideration of the portion of the court’s earlier order that denied summary judgment on Dr. Sari Edelman’s claims under the Equal Pay Act. Reconsideration is a request to change an earlier ruling. The court stated that such relief is available only when a party identifies a change in controlling law, new evidence, or a clear error or manifest injustice.
Arguments and Analysis
The court concluded that none of the matters raised in the motion had been overlooked in its earlier decision. The defendants argued that Dr. Edelman had set her own prior salary and that NYU had used that salary in assessing the future profitability of her practice. The court stated that these facts did not explain how her compensation was actually derived from her prior salary or how the higher salaries of her comparators were set. The court also found a factual dispute about whether the profitability assessment was affected by gender bias.
The defendants further argued that renewal salaries incorporated prior productivity bonuses and that the plaintiff’s method of comparing compensation on a per-work-relative-value-unit basis was improper. The court stated that the documentary evidence showed productivity bonuses increased compensation in proportion to the amount by which physicians’ work relative value units exceeded their targets. The court characterized the defendants’ arguments about renewal salaries and per-work-relative-value-unit compensation as contradictory and stated that a genuine dispute remained about whether differences in productivity-adjusted compensation resulted from permissible considerations rather than discrimination.
Ruling
Judge Lorna G. Schofield denied the defendants’ motion for reconsideration. The clerk was directed to close the motion at Docket Number 159. The opinion states that the remaining material factual disputes are to be resolved at trial.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.