Elon Musk and Tesla Tries to Revive $55 Billion Payment Package After Court Rejection

By: Jaenney Lee

Edited by: Lauren Levinson and Anna westfall

In January 2024, Chancellor Kathleen St. June McCormick ruled against Elon Musk regarding his possession of a landmark compensation package awarded by Tesla’s board of directors that is potentially worth more than $55 billion. The litigation began in 2018 when a shareholder lawsuit targeted Tesla CEO Musk and the company directors. They were charged with violating their obligations to the manufacturer of solar panels and electric cars, which led to the wastage of company funds and Musk’s unfair gain. [1] 

The payment package, according to the shareholder’s attorneys, should be void since Musk controlled it and resulted from fictitious talks with directors who were not impartial. Additionally, they claimed that shareholders who received inaccurate and deceptive disclosures in a proxy statement accepted it. [2]

On the other hand, the defense attorney argued that a compensation committee negotiated the payment plan with accurate disclosures,  where board members were independent of Musk. They added that Musk was not a controlling shareholder as his owned share was less than one-third of the company at the time. [3] 

The payment package was unique because it contained a large portion of stock options divided into twelve equal portions. The options’ payoff depended on on Tesla meeting three sets of progressively challenging growth objectives for its market value, revenue, and adjusted earnings (adjusted for specific expenses). Musk would get a portion of the prize money each time Tesla surpassed both the market value target and one of the other two objectives. When the package was first proposed in 2018, the goals seemed unachievable. However, as much as the achievement looked impossible, the payoff was equally promising – leading two-thirds of shareholders to approve the payment package. By the end of 2022, Tesla and Musk met enough goals for Musk to receive the entire $55 billion package.[4]

Tracing back to when he achieved to receive the entire package, the Court of Chancery in the state of Delaware, where Tesla’s headquarter is located, mentions that “Tesla’s stockholders claim that Elon Musk caused Tesla to overpay for SolarCity through his alleged domination and control of the Tesla board of directors.”[5] Additionally, the board members are required to put shareholders’ interests ahead of their own, which makes hiring, firing, and checking and balancing the CEO some of their important roles. However, as Musk gradually became a big shareholder due to the payment package, it became harder for Musk to be independent from the board members.[6] 

A month after the judge’s ruling, Musk stated that he would try to move Tesla’s corporate listing to Texas, where he has already moved company headquarters from Delaware. Moreover, with Neuralink, his privately held brain implant company, he moved the corporate listing from Delaware to Nevada. However, legal experts say that such a movement would not affect the payment case as the case remains to be actions taken while Tesla was incorporated in Delaware.[7][8]

Nearly four months after the ruling, on April 18, 2024, Tesla and Musk are attempting to revive his $55 billion payment plan by exploiting a cryptic corporate law rule. This is an unprecedented strategy that might land the business in litigation once more. Musk is making use of a little-known provision in Delaware corporation law that permits businesses to correct procedural errors that would nullify boardroom decisions. [9]

Professor Eric Talley of Columbia Law School stated that the purpose of the clause is not to overturn significant court decisions, but rather to serve as a “Band-Aid” for minor administrative errors.[10]

Musk’s strategy is not to address the shortcomings McCormick found in the negotiations for the payment plan. Rather,  proposed that they had an independent director of a “special committee,” Kathleen Wilson-Thompson, who reviewed the 2018 payment package and stated that it was in the “best interest of shareholders” to resolve the board conflicts. “We suggest simply subjecting the original 2018 package to a new shareholder vote, accompanied by extensive disclosure as to the process undertaken and the potential conflicts of interest that were considered at the time,” the special board committee’s report said.[11]

Furthermore, this process allows the shareholders to vote again for the payment package, and give them 120 days to challenge the proposal if it is approved again. Talley mentions that if shareholders approve, it may facilitate Musk’s appeal victory in the Delaware Supreme Court by shifting the burden of proof to the plaintiffs, who would then have to show that Musk’s compensation was unreasonable.[12]

While Musk and Tesla argue that the majority of the stockholders did not agree with the court’s decision in January, McCormick states that Musk would not be able to prove that shareholders were adequately informed about the deal for his appeal this time.[13]

Notes:

1. CHASE, RANDALL. 2024. “Elon Musk Pay Package from Tesla Denied by Delaware Judge.”January 30, 2024. 

2. CHASE, RANDALL. 2024. “Elon Musk Pay Package from Tesla Denied by Delaware Judge.” January 30, 2024. 

3. CHASE, RANDALL. 2024. “Elon Musk Pay Package from Tesla Denied by Delaware Judge.” January 30, 2024. 

4. Melin, Anders. “What You Need to Know about Elon Musk’s Voided $55 Billion Pay Package.” February 2, 2024.

5. Melin, Anders. “What You Need to Know about Elon Musk’s Voided $55 Billion Pay Package.” February 2, 2024. 

6. “IN RE TESLA MOTORS, INC.  STOCKHOLDER LITIGATION.” n.d. No. 181, 2022

7. KRISHER, TOM. “Tesla Wants Shareholders to Reinstate $56 Billion Pay Package for Musk Rejected by Delaware Judge.” April 17, 2024. 

8. Lukpat, Alyssa, Theo Francis, and Denny Jacob. “Tesla Tries to Revive Elon Musk’s Big Payday after Court Rejected It.” April 17, 2024. 

9. Lukpat, Alyssa, Theo Francis, and Denny Jacob. “Tesla Tries to Revive Elon Musk’s Big Payday after Court Rejected It.” April 17, 2024.

10. Hals, Tom, and Jody Godoy. “Tesla Tries Legal ‘Band-Aid’ to Revive Musk’s Huge Pay Deal.” April 18, 2024. 

11. Hals, Tom, and Jody Godoy. “Tesla Tries Legal ‘Band-Aid’ to Revive Musk’s Huge Pay Deal.” April 18, 2024. 

12. Lukpat, Alyssa, Theo Francis, and Denny Jacob. “Tesla Tries to Revive Elon Musk’s Big Payday after Court Rejected It.” April 17, 2024. 

13.  Lukpat, Alyssa, Theo Francis, and Denny Jacob. “Tesla Tries to Revive Elon Musk’s Big Payday after Court Rejected It.” April 17, 2024. 

 Bibliography:

Chase, Randall. 2024. “Elon Musk Pay Package from Tesla Denied by Delaware Judge.” AP News. AP News. January 30, 2024. 

Hals, Tom, and Jody Godoy. 2024. “Tesla Tries Legal ‘Band-Aid’ to Revive Musk’s Huge Pay Deal.” Reuters. April 18, 2024. 

“In The Supreme Court Of The State Of Delaware.” In Re Tesla Motors, Inc.  Stockholder Litigation. n.d. No. 181, 2022 C.A. No. 12711

Krisher, Tom. 2024. “Tesla Wants Shareholders to Reinstate $56 Billion Pay Package for Musk Rejected by Delaware Judge.” Opb. OPB. April 17, 2024. 

Lukpat, Alyssa, Theo Francis, and Denny Jacob. 2024. “Tesla Tries to Revive Elon Musk’s Big Payday after Court Rejected It.” WSJ. The Wall Street Journal. April 17, 2024. 

Melin, Anders. 2024. “What You Need to Know about Elon Musk’s Voided $55 Billion Pay Package.” The Seattle Times. February 2, 2024.

What Can We Expect From Biden’s SAVE Plan?

By: Alexandria Henriquez

Edited by: Samantha yip and Ananya Chag

Over the last 3 years of his presidential term, following through on his campaign promises, Biden has pushed through several executive actions forgiving $146 billion in student debt. [1] The most recent addition to Biden’s student loan forgiveness initiative is the Saving on a Valuable Education (SAVE) Plan, an income-driven repayment (IDR) plan that amends the Revised Pay As You Earn (REPAYE) Plan. Those already holding undergraduate loans under the REPAYE plan will “have their payments reduced from 10% to 5% of their discretionary income,” and those with both undergraduate and graduate loans will pay something in between. By redefining discretionary income, the SAVE Plan also brings many individuals’ monthly loan payments to $0. Finally, borrowers under the SAVE plan will not have their loans grow from unpaid interest, and original loans of $12,000 or smaller will receive full forgiveness after 10 years of repayment. For each additional $1,000 borrowed, the plan adds an additional year of repayment. [2]

The SAVE plan comes as a response to Biden’s previous loan forgiveness plan. In June 2023, the Supreme Court nullified Biden’s federal loan forgiveness plan that would have forgiven up to $10,000 in student loans for Americans with incomes below $125,000 and up to $20,000 for those with Pell Grants. [3] The Biden Administration claims the ability to implement federal student loan forgiveness plans from the Higher Education Relief Opportunities for Students Act of 2003 (HEROES Act), which allows the Secretary of Education to “waive or modify any statutory or regulatory provision applicable to the student financial assistance programs under title IV of the Act as the Secretary deems necessary in connection with a war or other military operation or national emergency.” [4] The statute that the Biden Administration claimed to be modifying, using the HEROES Act, is The Higher Education Act of 1965 (Education Act). The Higher Education Act was originally created to increase accessibility to educational opportunities by developing a federal financial aid program and three types of federal student loans. In Biden v. Nebraska, the Supreme Court found that Biden’s plan to dismiss almost $20,000 of loans for certain borrowers went too far and could not be seen as a “modification.” They found that “the Act allows the Secretary to ‘waive or modify’ existing statutory or regulatory provisions applicable to financial assistance programs under the Education Act, not to rewrite that statute from the ground up.” [5] The court identified that significant loan forgiveness action was taken in response to the COVID–19 pandemic, and the timing of the new program was somewhat suspicious, since “over a year and a half passed with no further action beyond keeping the repayment and interest suspensions in place.” [6] Moreover, the Department of Education announced the waivers and modifications only a few weeks before Biden announced that the “pandemic is over.” [7]

This leaves us wondering whether a similar case or ruling will arise with the new SAVE plan. As of April 2024, eighteen states have filed a lawsuit against Biden, the Department of Education, and Secretary of Education Miguel Cardona to shut down the plan. [8] The two suits, split among the 18 states, argue that the Secretary of Education has overstepped again. However, a key difference between Biden’s recently rejected plan and the new SAVE plan is the SAVE plan’s format as a repayment plan. Nonetheless, its high stakes might provide a reason for the courts to require congressional approval.

Notes:

1. “President Joe Biden Outlines New Plans to Deliver Student Debt Relief to Over 30 Million Americans under the Biden-Harris Administration,” The White House, April 8, 2024, https://www.whitehouse.gov/briefing-room/statements-releases/2024/04/08/president-joe-biden-outlines-new-plans-to-deliver-student-debt-relief-to-over-30-million-americans-under-the-biden-harris-administration/. 

2. “Fact Sheet: The Biden-Harris Administration Launches The Save Plan, the Most Affordable Student Loan Repayment Plan Ever to Lower Monthly Payments for Millions of Borrowers.” The White House, August 22, 2023. https://www.whitehouse.gov/briefing-room/statements-releases/2023/08/22/fact-sheet-the-biden-harris-administration-launches-the-save-plan-the-most-affordable-student-loan-repayment-plan-ever-to-lower-monthly-payments-for-millions-of-borrowers/. 

3. Biden v. Nebraska, 600 U.S. 477, (2023), 2.

4. Higher Education Relief Opportunities For Students Act of 2003, Pub. L. No. 108-76, 117 Stat. 904 (2003).

5. Biden v. Nebraska, 600 U.S. 477, (2023), 12.

6. Biden v. Nebraska, 600 U.S. 477, (2023), 5.

7. Scott Pelley, “President Joe Biden: The 2022 60 Minutes Interview,” CBS News, September 18, 2022, https://www.cbsnews.com/news/president-joe-biden-60-minutes-interview-transcript-2022-09-18/. 

8. Tara Siegel Bernard, “Biden’s Student Loan Repayment Plan Is Being Challenged. Here’s What to Know.” The New York Times, April 13, 2024, https://www.nytimes.com/2024/04/13/business/biden-save-student-loans-courts.html. 

Bibliography:

Biden v. Nebraska, 600 U.S. 477, (2023)

“Fact Sheet: The Biden-Harris Administration Launches The Save Plan, the Most Affordable Student Loan Repayment Plan Ever to Lower Monthly Payments for Millions of Borrowers.” The White House, August 22, 2023. https://www.whitehouse.gov/briefing-room/statements-releases/2023/08/22/fact-sheet-the-biden-harris-administration-launches-the-save-plan-the-most-affordable-student-loan-repayment-plan-ever-to-lower-monthly-payments-for-millions-of-borrowers/. 

Higher Education Relief Opportunities For Students Act of 2003, Pub. L. No. 108-76, 117 Stat. 904, (2003).

Pelley, Scott. “President Joe Biden: The 2022 60 Minutes Interview.” CBS News, September 18, 2022. https://www.cbsnews.com/news/president-joe-biden-60-minutes-interview-transcript-2022-09-18/. 

“President Joe Biden Outlines New Plans to Deliver Student Debt Relief to Over 30 Million Americans under the Biden-Harris Administration,” The White House, April 8, 2024, https://www.whitehouse.gov/briefing-room/statements-releases/2024/04/08/president-joe-biden-outlines-new-plans-to-deliver-student-debt-relief-to-over-30-million-americans-under-the-biden-harris-administration/. 

Bernard, Tara. “Biden’s Student Loan Repayment Plan Is Being Challenged. Here’s What to Know.” The New York Times, April 13, 2024. https://www.nytimes.com/2024/04/13/business/biden-save-student-loans-courts.html. 

The Eviction and Homelessness Crisis: Has the Supreme Court Bitten Off More than it Can Chew?

By: Ana Cucalon

Edited by: Alexandria Ragy and Valerie Chu

The impending Supreme Court case regarding homelessness rules in Oregon serves as a poignant reminder of the interconnectedness between homelessness, evictions, and the broader issue of inequality within the American justice system. As the nation grapples with a growing homelessness epidemic and an escalating eviction crisis, it becomes imperative to understand the underlying causes and their legal ramifications. This article seeks to delve into the complex dynamics at play, drawing upon recent scholarship to explore how rising levels of inequality perpetuate the cycle of evictions and homelessness, consequently exacerbating the justice system crisis.

The case before the Supreme Court revolves around the legality of homelessness in American cities, specifically in Oregon where the case is centered. At its core lies the tension between municipal ordinances wishing to regulate the use of public spaces and the constitutional rights of homeless individuals, namely their right to sleep. The case is set to address an issue so contested that it has united Democrat and Republican politicians as they plead to the Supreme Court for clarification as to how the homelessness crisis should be addressed. Specifically, they want two things to be made clear: what constitutes an adequate shelter, and what constitutes involuntary homelessness. [1]

The Oregon case began in Boise, Idaho, where a homeless group sued the city for violating the Eighth Amendment. After being fined for sleeping in a public space, the group argued that because the city did not have adequate shelter beds, they were involuntarily homeless. Therefore, they argued they should not be punished for sleeping in public spaces as it is an “unusual and cruel punishment” to criminalize the need to sleep. [2] They won their case, and when the defendants appealed to the Supreme Court they were denied. The case, titled Martin v. Boise, is the basis for the case in Grants Pass. There, homeless people were increasingly fined for sleeping on sidewalks and in parks, facing incarceration were they to repeat the offense. Many of them were incapable of paying the fines so stayed in the parks. They proceeded to sue the city, stating that they were violating the Constitution based on the legal precedent set in Martin v. Boise. They argued that they were subject to the same involuntary homelessness described in the case, as Grant Pass did not provide adequate shelter for them to reside. [3] The Oregon case raises three important questions plaguing the American justice system: can cities make it illegal to be homeless? Why is there an increase in homelessness? Is there a deeper issue propelling the crisis at hand?

Legal scholars Colleen Shanahan and Anna Carpenter would argue that there is, and the issue is inequality. Their research underscores how structural disparities within the legal system disproportionately disadvantage marginalized groups, leading to a proliferation of evictions. They discuss how due to rising levels of poverty, increases in rent, and disproportionately poor conditions in underprivileged neighborhoods, people are continuously forced out of their homes. [4] Sociologist Matthew Desmond said this downward residential mobility also propels negative effects such as “adolescent violence, poor school performances, and health risks” (Desmond 89). [5] This reveals a systematic cycle of poverty and inequality, which no matter the attempts to address homelessness and the eviction crisis, continue to exacerbate the burdens on the justice system. In their article "Simplified Courts Can’t Solve Inequality," Shanahan and Carpenter argue that these problems of inequality can’t be solved through legislation. Instead, they believe social safety nets are better equipped to address the issues of systemic poverty that propel homelessness and eviction. [6]

Therefore, it is important to question whether or not the Supreme Court can tackle the issue of homelessness. The strain on the justice system caused by eviction demonstrates that the Court may need to be more capable of addressing the issue it is presented with. Overburdened courts and inadequate legal representation for vulnerable populations perpetuate systemic injustices. Recent research underscores the urgent need for systemic reforms to mitigate the adverse effects of inequality within the justice system.

In conclusion, the eviction and homelessness crises plaguing America's justice system are symptomatic of deeper societal inequities. By examining the interplay between rising inequality, evictions, and homelessness, scholars have uncovered systemic flaws that perpetuate cycles of poverty and marginalization. As the Supreme Court prepares to navigate the legal complexities surrounding homelessness regulations, it may be necessary for policymakers, advocates, and communities to prioritize solutions that address the root causes of inequality.

Notes:

1. Abbie VanSickle, "Supreme Court to Hear Case Over Homelessness Rules in Oregon," New York Times, September 27, 2023.

2. "The Supreme Court Takes Up Homelessness," The Daily, podcast audio, New York Times, November 3, 2023.

3. VanSickle, "Supreme Court to Hear Case Over Homelessness Rules in Oregon,"

4. Shanahan and Carpenter, "Lawyerless Law Development," Journal of Law and Social Inquiry 42, no. 3 (Summer 2017): 567-589.

5. Matthew Desmond, "Eviction and the Reproduction of Urban Poverty" (Ph.D. diss., University of Wisconsin-Madison, 2010).

6. Shanahan and Carpenter, "Simplified Courts Can't Solve Inequality," Stanford Law Review 69, no. 2 (February 2017): 423-445.

Bibliography:

Desmond, Matthew. 2012."Eviction and the Reproduction of Urban Poverty." American Journal of Sociology, Vol. 118, No. 1.

Shanahan, and Carpenter. 2023. "Lawyerless Law Development." Stanford Law Review, no. 3: 567-589.

Shanahan, and Carpenter. 2019. "Simplified Courts Can't Solve Inequality." Journal of Law and Social Inquiry, no. 2: 423-445.

The Daily, New York Times. 2024. "The Supreme Court Takes Up Homelessness." https://www.nytimes.com/2024/04/19/podcasts/the-daily/supreme-court-homelessness.html

VanSickle, Abbie. 2024. "Supreme Court to Hear Case Over Homelessness Rules in Oregon." New York Times. https://www.nytimes.com/2024/01/12/us/politics/supreme-court-homeless-camps-oregon.html

Caitlin Clark and the Future of Wage Disparities in Women’s Sports

By: Eliana Aero Selassie

Edited by: regan Cornelius and Isabella canales

Caitlin Clark, point guard for the University of Iowa’s women’s basketball team, has revolutionized college sports in the last year. With 3,951 career points, Clark is the leading scorer in the history of college basketball. [1] The NCAA women’s basketball championship game between the Iowa Hawkeyes and the University of South Carolina Gamecocks broke records by being the most-watched basketball game in the last 5 years, which averaged 18.7 million viewers and 24 million at its peak. The Iowa game pulled 4 million more viewers than the men’s NCAA final for the first time as a result of Clark’s incredible performance in the last year. [2] The Iowa game was the most-watched basketball game in the history of ESPN and this dramatic increase in viewership has brought women’s basketball to new levels of praise and viewership. [3]

Clark was selected as the WNBA's Number 1 draft pick and is now set to play for the Indiana Fever. Despite her record achievements and strong career ahead of her, many were shocked to discover her remarkably low salary for a record-breaking athlete of her stature. Clark’s rookie contract is $338,056 over 4 years, totaling $84,500 annually. Her salary is starkly lower than NBA No. 1 draft pick Victor Wembanyama, whose salary is $55.2 million over the next 4 years. This is largely a result of structural issues between the WNBA and the NBA that contribute to severe pay inequality. Players’ salaries are usually a product of annual revenue from each league, consisting of television and broadcasting rights, sponsorships, and ticket and merchandise purchases. [4] The NBA annually earns roughly $10 billion in revenue, which is fifty times greater than the WNBA's revenue of $200M. Additionally, the NBA also plays for a considerably longer season, with 82 games compared to 40 for the WNBA. Because the NBA plays significantly more games, it is able to generate more annual revenue and play its players more. However, given that the WNBA plays fewer games, it makes significantly less in annual revenue, thereby restricting the amount of money available for player’s salaries. [5]

Another important factor is collective bargaining agreements (CBA). The NBA’s CBA allows players to receive 50 percent of all the revenue the league generates, creating a substantial pool for their salaries. In contrast, WNBA players receive 50 percent of “incremental revenue” which is known as “revenue that exceeds the targets the league has set for itself”. [5] This provides a much smaller pool for their salaries to be drawn from, in addition to the significantly lower amount of annual revenue that the WNBA makes compared to the NBA. In total, this also means that only 20 percent of the revenue the WNBA generates goes toward players' salaries. [5]

President Biden was among the fans disheartened by Clark’s low salary, sharing on the social media platform X that “Right now we’re seeing that even if you’re the best, women are not paid their fair share. It’s time that we give our daughters the same opportunities as our sons and ensure women are paid what they deserve”. [6] Women earn around 15 to 100% less than their male counterparts in sports like basketball, soccer, tennis, and golf. Conversations over this disparity in sports were catapulted by the significant inequalities between the payment and treatment of male and female soccer teams. During the 2022 Men’s World Cup, the winner’s prize pool was $440 million, while in the 2023 Women’s World Cup, the pool was $110 million, a quarter less. However, despite these stark differences, the gap between male and female athletes is the most blatant between the WNBA and the NBA. In the 2022-2023 season, NBA players had a minimum salary of $953,000 and a maximum salary of $45,780,966, while the WNBA had a minimum salary of $60,000 and a maximum salary of $234,936. [7]

Caitlin Clark and wage discrepancies in the WNBA compared to their male counterparts in the NBA are indicative of a larger issue of wage inequality in the workplace. In the United States, for every dollar a man makes, a woman earns 84 cents. [8] The wage gap is even more stark for women of color, where black and Latina women who work full time are paid, respectively, 69 cents and 57 cents for every dollar a white man makes. These discrepancies have persisted despite legislation and legal efforts enacted to address the wage gap. [9]

The Equal Pay Act (EPA), passed in 1963, bars discrimination between men and women who work the same jobs with the same skills, effort, responsibility, and working conditions. The act “prohibits discrimination on account of sex in the payment of wages by employers.” Nonetheless, the act’s enforcement and application have been significantly ineffective because many of its features lack enforcement mechanisms to hold corporations responsible for the wage gap. The EPA fails to outline provisions for fair compensation of victims of wage discrepancies and interpretations of the EPA have been very inconsistent in defining “a work establishment,” which has allowed employers to pay unequal wages to men and women because they can take advantage of these inconsistent interpretations and pay their workers in a manner of their choosing. The act also provides weak class action provisions, making it hard for victims of discrimination to carry out lawsuits. 

More recent political and legal efforts to amend the wage gap have also been unsuccessful at tackling the issue. In the 2007 Supreme Court case Ledbetter v. Goodyear Tire & Rubber Co., it was stated that employees could not sue their employers for pay discrimination under Title VII of the Civil Rights Act of 1964 if they had not filed the suit “within 180 days of a discriminatory salary decision”. [11] The Ledbetter case marked a substantial judicial setback in achieving equal pay since the capacity and agency of women to receive compensation for wage discrimination was significantly reduced, illustrating a lack of success in recent attempts to resolve these inequalities.  Most recently, the Paycheck Fairness Act (PFA) was reintroduced into the House and the Senate in March 2023 after failing to pass through the Senate in 2021. The PFA helps address many of the EPA’s weaknesses, providing a clear definition of a work “establishment”, improving class action provisions, and providing stronger enforcement mechanisms. [10]      

Despite significant setbacks, Clark’s rapid impact on women’s basketball could alter the future of WNBA wages and the league’s reputation. Teams set to play the Fever have begun to see an increase in ticket sales, and her Indiana Fever jersey is fully sold out. Furthermore, teams playing Clark and the Fever are already expanding to larger stadiums to accommodate increased viewer turnout. Clark’s presence in the WNBA has rapidly grown its fanbase and increased awareness of the wage and resource inequality that female basketball players face. [12] Many players are hopeful that this is the start of much-needed change in the WNBA and the treatment of female athletes everywhere. The debate over Clark’s salary could also be an important step toward introducing and enforcing legislation that amends the wage gap across workplaces. 

Notes:

1. Reynolds, Tim. “Caitlin Clark's college career, by the numbers.” AP News, 8 April 2024, https://apnews.com/article/caitlin-clark-iowa-ncaa-1d88d50c2db783b6e5b075e7243dcc85. Accessed 8 May 2024.

2. “Caitlin Clark – University of Iowa Athletics.” n.d. Iowa Athletics. Accessed April 23, 2024. https://hawkeyesports.com/roster/caitlin-clark/.

3. Matthews, Alex L. 2024. “How women’s NCAA basketball and Caitlin Clark broke viewership records, in three charts.” CNN. https://www.cnn.com/2024/04/10/us/ncaa-womens-basketball-ratings-dg/index.html.

4. Gregory, Sean. 2024. “Caitlin Clark's Legacy Is Untarnished After Final NCAA Game.” Time. https://time.com/6964487/caitlin-clark-ncaa-championship-legacy/.

5. Johnson, Roy. 2024. “Misplaced outrage over WNBA contract should spark change.” Las Vegas Sun. https://lasvegassun.com/news/2024/apr/20/misplaced-outrage-over-wnba-contract-should-spark/. 

6. Zhou, Li. 2024. “Caitlin Clark's staggeringly low starting salary, briefly explained.” Vox. https://www.vox.com/24132057/caitlin-clark-wnba-draft-2024. 

7. Vigdor, Neil. 2024. “Biden Weighs in on Caitlin Clark Salary Debate After W.N.B.A. Draft.” The New York Times. https://www.nytimes.com/2024/04/17/us/politics/caitlin-clark-salary-biden.html. 

8. Adelphi University. 2023. “Male vs. Female Professional Sports Salary Comparison.” Online Programs. https://online.adelphi.edu/articles/male-female-sports-salary/. 

9. Sahadi, Jeanne. 2024. “March 12 marks Equal Pay Day this year.” CNN. https://www.cnn.com/2024/03/12/success/equal-pay-day-2024/index.html. 

10. “The Simple Truth about the Pay Gap.” n.d. AAUW. Accessed April 23, 2024. https://www.aauw.org/resources/research/simple-truth/. 

11. American Bar Association. n.d. “The Paycheck Fairness Act.” American Bar Association. Accessed April 23, 2024. https://www.americanbar.org/advocacy/governmental_legislative_work/priorities_policy/discrimination/the-paycheck-fairness-act/. 

12. Oyez, 2024. “Ledbetter v. Goodyear Tire and Rubber Company.” https://www.oyez.org/cases/2006/05-1074. 

13. Treisman, Rachel. 2024. “Caitlin Clark and Fever frenzy hit the WNBA, boosting ticket prices and jersey sales.” NPR. https://www.npr.org/2024/04/22/1246308836/caitlin-clark-indiana-fever-wnba-tickets-venues. 

Bibliography:

Adelphi University. 2023. “Male vs. Female Professional Sports Salary Comparison.” Online Programs. https://online.adelphi.edu/articles/male-female-sports-salary/.

American Bar Association. n.d. “The Paycheck Fairness Act.” American Bar Association. Accessed April 23, 2024. https://www.americanbar.org/advocacy/governmental_legislative_work/priorities_policy/discrimination/the-paycheck-fairness-act/.

Gregory, Sean. 2024. “Caitlin Clark's Legacy Is Untarnished After Final NCAA Game.” Time. https://time.com/6964487/caitlin-clark-ncaa-championship-legacy/.

Johnson, Roy. 2024. “Misplaced outrage over WNBA contract should spark change.” Las Vegas Sun. https://lasvegassun.com/news/2024/apr/20/misplaced-outrage-over-wnba-contract-should-spark/.

Matthews, Alex L. 2024. “How women’s NCAA basketball and Caitlin Clark broke viewership records, in three charts.” CNN. https://www.cnn.com/2024/04/10/us/ncaa-womens-basketball-ratings-dg/index.html.

Oyez, 2024. “Ledbetter v. Goodyear Tire and Rubber Company.” https://www.oyez.org/cases/2006/05-1074.

Reynolds, Tim. “Caitlin Clark's college career, by the numbers.” AP News, 8 April 2024, https://apnews.com/article/caitlin-clark-iowa-ncaa-1d88d50c2db783b6e5b075e7243dcc85. Accessed 8 May 2024.

Sahadi, Jeanne. 2024. “March 12 marks Equal Pay Day this year.” CNN. https://www.cnn.com/2024/03/12/success/equal-pay-day-2024/index.html.

“The Simple Truth about the Pay Gap.” n.d. AAUW. Accessed April 23, 2024. https://www.aauw.org/resources/research/simple-truth/.

Treisman, Rachel. 2024. “Caitlin Clark and Fever frenzy hit the WNBA, boosting ticket prices and jersey sales.” NPR. https://www.npr.org/2024/04/22/1246308836/caitlin-clark-indiana-fever-wnba-tickets-venues.

Vigdor, Neil. 2024. “Biden Weighs in on Caitlin Clark Salary Debate After W.N.B.A. Draft.” The New York Times. https://www.nytimes.com/2024/04/17/us/politics/caitlin-clark-salary-biden.html.

Zhou, Li. 2024. “Caitlin Clark's staggeringly low starting salary, briefly explained.” Vox. https://www.vox.com/24132057/caitlin-clark-wnba-draft-2024.