CACI 2742 Bona Fide Factor Other Than Sex, Race, or Ethnicity

California Civil Jury Instructions CACI

2742 Bona Fide Factor Other Than Sex, Race, or Ethnicity


[Name of defendant] claims that [specify bona fide factor other than sex, race, or ethnicity] is a legitimate factor other than [sex/race/ethnicity] that justifies paying [name of plaintiff] at a wage rate that is less than the rate paid to employees of [the opposite sex/another race/another ethnicity].

[Specify factor] is a factor that justifies the pay differential only if [name of defendant] proves all of the following:

1.That the factor is not based on or derived from a [sex/race/ethnicity]-based differential in compensation;

2.That the factor is job related with respect to [name of plaintiff]’s position; and

3.That the factor is consistent with a business necessity.

A “business necessity” means an overriding legitimate business purpose such that the factor effectively fulfills the business purpose it is supposed to serve.

This defense does not apply, however, if [name of plaintiff] proves that an alternative business practice exists that would serve the same business purpose without producing the pay differential.


Directions for Use

This instruction must be given along with CACI No. 2741, Affirmative Defense—Different Pay Justified, if factor d of element 1 of CACI No. 2741 is chosen: a bona fide factor other than sex, race, or ethnicity, such as education, training, or experience. This factor applies only if the employer demonstrates that the factor is not based on or derived from a sex, race, or ethnicity-based differential in compensation, is job-related with respect to the position in question, and is consistent with a business necessity. “Business necessity” means an overriding legitimate business purpose such that the factor effectively fulfills the business purpose it is supposed to serve. This defense does not apply if the employee demonstrates that an alternative business practice exists that would serve the same business purpose without producing the wage differential. (See Lab. Code, § 1197.5(a)(1)(D), (b)(1)(D).)


Sources and Authority

Bona Fide Factor Other Than Sex, Race, or Ethnicity. Labor Code section 1197.5(a)(1)(D), (b)(1)(D).


Secondary Sources

3 Witkin, Summary of California Law (11th ed. 2017) Agency and Employment, §§ 355 et seq., 430, 431
Chin et al., California Practice Guide: Employment Litigation, Ch. 11-G, Compensation—Wage Discrimination, ¶ 11:1077.10 et seq. (The Rutter Group)
3 Wilcox, California Employment Law, Ch. 43, Civil Actions Under Equal Employment Opportunity Laws, § 43.02 (Matthew Bender)
21 California Forms of Pleading and Practice, Ch. 250, Employment Law: Wage and Hour Disputes, § 250.14 (Matthew Bender)