Employment Litigation · Primary-source case analysis

Manhart: Sex-Based Pension Contributions Violated Title VII Despite Group Longevity Statistics

By Aneeta Mishra and Timothy Chan

Published May 22, 2026

City of Los Angeles Department of Water and Power v. Manhart involved a pension plan that charged women more because women as a class were expected to live longer, although benefits were equal for individual retirees.

Title VII focused on individual treatment

An employer could not charge an individual woman more merely because women on average lived longer than men.

Accurate group statistics did not authorize sex pricing

Even a real average difference could not justify a contribution rule that classified every employee by sex.

Equal benefits did not cure unequal pay deductions

The higher required contribution reduced women’s take-home compensation for the same promised pension.

Retroactive relief was limited

The Court upheld prospective liability but rejected the broad refund award after weighing the plan’s reliance and financial consequences.

Key takeaways

• Compare employee contributions for the same benefit.
• Identify every explicit sex-based classification.
• Do not substitute group averages for individual treatment.
• Analyze prospective correction separately from retroactive monetary relief.