University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Beckmann v. CBS Inc. EE-MN-0083
Docket / Court 3:96-cv-01172 ( D. Minn. )
State/Territory Minnesota
Case Type(s) Equal Employment
Special Collection IWPR/Wage Project Consent Decree Study
Private Employment Class Actions
Case Summary
On December 12, 1996, four female technical employees at a various CBS television studios filed a lawsuit under both Title VII of the Civil Rights Act, 42 U.S.C. § 2000e et. seq., and the Minnesota Human Rights Act ("MHRA"), Minn. Stat. § 363.01 et. seq. against CBS, Inc. in the United States ... read more >
On December 12, 1996, four female technical employees at a various CBS television studios filed a lawsuit under both Title VII of the Civil Rights Act, 42 U.S.C. § 2000e et. seq., and the Minnesota Human Rights Act ("MHRA"), Minn. Stat. § 363.01 et. seq. against CBS, Inc. in the United States District Court of the District of Minnesota.

The plaintiffs, represented by private counsel, asked the court for monetary damages and injunctive relief, charging the Company with discriminating against female employees. Plaintiffs allege the defendant systematically discriminated against female technical employees in assignments, promotions, training, and overtime, and by maintaining a hostile work environment. According to plaintiffs' expert analysis, "women tend to be concentrated in the lower paying per diem jobs, instead of staff jobs [charts omitted]. During 1993-98, women held between 22% and 27% of per diem positions, but 15-17% of staff jobs. Per diem employees earn about 1/4 as much as staff employees, on the average. Both of these patterns are consistent across stations."

On August 13, 1997, both parties filed a joint motion to dismiss. This motion was denied on September 12, 1997. On October 13, 1998, plaintiffs filed an amended complaint. On March 18, 1999 plaintiffs filed a second amended complaint.

On August 23, 1999, defendant filed motion for summary judgment. On September 3, 1999, plaintiffs filed motion for class certification. On March 31, 2000, the court (Judge Arthur J. Boylan) issued an order granting plaintiffs' motion for class certification, and denying defendant's motion for summary judgment. The class was certified as follows:

"Females who are or have been employed by CBS as technicians at WCCO-TV or in the Engineering and Operation Department at KCBS-TV, WCBS-TV, WBBM-TV, or WFRV-TV [**27] for the time period of October 6, 1993 to present who have been, continue to be, or may in the future be discriminated against because of their sex with respect to assignments, promotion, training or overtime; or for the time period of July 5, 1995 to present who have been, continue to be, or may in the future be discriminated against because of their sex with respect to a hostile environment. As it relates to the discrimination as to overtime, the class is limited to female full-time technical employees. "

On November 1, 2000, the parties entered a consent decree, settling the case for $8.1 million and injunctive relief. The injunctive relief included additional training for female technicians, job posting requirements, employee interest surveys, changes in the manner of overtime and other sought-after job assignments and other matters designed to further the careers of female technicians at CBS and the six covered CBS-owned stations: WCCO-TV, KCBS-TV, WCBS-TV, WBBM-TV, WFRV-TV, and WWJ-TV.

On October 25, 2000, plaintiffs filed motion requesting preliminary approval of a consent decree. On November 17, 2000 this motion was granted, and on January 22, 2001, the court (Judge Boylan) ordered for final approval of the consent decree, closing the case.

We have not found a copy of the Consent Decree; the PACER docket live links start after its entry.

The Consent Decree was effective through January 19, 2005.

Julianne Nowicki - 07/25/2010


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Issues and Causes of Action
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Issues
Affected Gender
Female
Content of Injunction
Comply with advertising/recruiting requirements
Develop anti-discrimination policy
Follow recruitment, hiring, or promotion protocols
Monitor/Master
Monitoring
Provide antidiscrimination training
Reporting
Discrimination-area
Discipline
Harassment / Hostile Work Environment
Hiring
Other Conditions of Employment (including assignment, transfer, hours, working conditions, etc)
Pay / Benefits
Promotion
Discrimination-basis
Sex discrimination
General
Disparate Treatment
Pattern or Practice
Causes of Action Title VII (including PDA), 42 U.S.C. § 2000e
Defendant(s) CBS, Inc.
Plaintiff Description Female CBS technical employees for the time period of October 6, 1993 to present who have been, continue to be, or may in the future be discriminated against because of their sex with respect to assignments, promotion, training or overtime.
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Mixed
Public Int. Lawyer No
Nature of Relief Damages
Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration not on record
Case Closing Year 2001
Case Ongoing No
Additional Resources
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Case Studies Megacases, Diversity, and the Elusive Goal of Workplace Reform
Written: Mar. 01, 2008
By: Nancy Levit (University of Missouri-Kansas City School of Law)
Citation: 49 B.C. L. Rev. 367 (2008)
[ Detail ] [ External Link ]

  Second Generation Employment Discrimination: A Structural Approach
By: Susan Sturm (Columbia Law School)
Citation: 101 Colum. L. Rev. 458 (2001)
[ Detail ] [ External Link ]

Docket(s)
3:96-cv-01172 (D. Minn.) 05/26/2005
EE-MN-0083-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Order Granting Class Certification, Denying Defendant's Motion for Summary Judgment 03/31/2000 (192 F.R.D. 608) (D. Minn.)
EE-MN-0083-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Order for Preliminary Approval of Consent Decree 11/17/2000 (D. Minn.)
EE-MN-0083-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order for Final Approval of Consent Decree 01/22/2001 (D. Minn.)
EE-MN-0083-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Boylan, Arthur J. (D. Minn.) [Magistrate]
EE-MN-0083-9000
Frank, Donovan W. (D. Minn.)
EE-MN-0083-0001 | EE-MN-0083-0002 | EE-MN-0083-0003 | EE-MN-0083-9000
Monitors/Masters None on record
Plaintiff's Lawyers Boler, Jean M. (Washington)
EE-MN-0083-9000
Lang, Jane (District of Columbia)
EE-MN-0083-9000
Lieder, Michael D. (District of Columbia)
EE-MN-0083-9000
Schaefer, Lawrence P. (Minnesota)
EE-MN-0083-9000
Sprenger, Paul (District of Columbia)
EE-MN-0083-9000
Stokes, Susan E. (Minnesota)
EE-MN-0083-9000
Stratton, Lisa C (Minnesota)
EE-MN-0083-9000
Thompson, Mara R (Minnesota)
EE-MN-0083-9000
Defendant's Lawyers Engdahl, Kathryn M (Minnesota)
EE-MN-0083-9000
Goldstein, David J. (Minnesota)
EE-MN-0083-9000
Howard, Connie L. (Minnesota)
EE-MN-0083-9000
Leifer, Elihu (District of Columbia)
EE-MN-0083-9000
Leske, Corina L. (New York)
EE-MN-0083-9000
Lowy, Susanna M (New York)
EE-MN-0083-9000
Robbins, Howard Z. (New York)
EE-MN-0083-9000
Samples, James McClellan (Minnesota)
EE-MN-0083-9000
Stracher, Cameron A. (District of Columbia)
EE-MN-0083-9000
Stumo, Mary E. (Minnesota)
EE-MN-0083-9000
Will, Jennifer L Hakin (Minnesota)
EE-MN-0083-9000
Zimmerman, Lloyd B. (Minnesota)
EE-MN-0083-9000
Other Lawyers Culberth, Celeste E. (Minnesota)
EE-MN-0083-9000

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