On April 9, 2018, the U.S. Court of Appeals for the Ninth Circuit held in Rizo v. Yovino that prior salary alone—or in combination with other factors—cannot justify a wage differential between male and female employees under the Equal Pay Act. No. 16-15372 (Apr. 9, 2018). This Rizo decision overturns a 2017 Ninth Circuit decision, which held that prior salary was a permissible “factor other than sex” under the Equal Pay Act. The Rizo decision is now the federal law across the Ninth Circuit jurisdiction - Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington.