Ledbetter v. Goodyear Tire & Rubber Co.

Ledbetter v. Goodyear Tire & Rubber Co
Supreme Court of the United States
Argued November 27, 2006 Decided May 29, 2007
Full case name	Ledbetter v. Goodyear Tire & Rubber Co., Inc.
Docket nos.	05-1074
Citations	550 U.S. 618 (more)
Prior history	Judgment for Plaintiff, (N.D. Ala.); rev'd, 421 F. 3d 1169 (11th Cir. 2005), cert granted, 548 U.S. ___ (2006)
Holding
The equal pay for equal work discrimination charging period is triggered when a discrete unlawful practice takes place. A new violation does not occur, and a new charging period does not commence, upon the occurrence of subsequent non-discriminatory acts that entail adverse effects resulting from the past discrimination. Eleventh Circuit affirmed.
Court membership
Case opinions
Majority	Alito, joined by Roberts, Scalia, Kennedy, Thomas
Dissent	Ginsburg, joined by Stevens, Souter, Breyer
Laws applied
Civil Rights Act of 1964, Equal Pay Act of 1963
Superseded by
Lilly Ledbetter Fair Pay Act of 2009

Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007), is an employment discrimination decision of the Supreme Court of the United States. Employers cannot be sued under Title VII of the Civil Rights Act of 1964 over race or gender pay discrimination if the claims are based on decisions made by the employer 180 days ago or more. Justice Alito held for the five-justice majority that each paycheck received did not constitute a discrete discriminatory act, even if affected by a prior decision outside the time limit. Ledbetter's claim of the “paycheck accrual rule” was rejected [1]. The decision did not prevent plaintiffs from suing under other laws, like the Equal Pay Act, which has a three-year deadline for most sex discrimination claims, or 42 U.S.C. 1981, which has a four-year deadline for suing over race discrimination.

This was a case of statutory rather than constitutional interpretation, explaining the meaning of a law, not its constitutionality. The plaintiff in this case, Lilly Ledbetter, characterized her situation as one where "disparate pay is received during the statutory limitations period, but is the result of intentionally discriminatory pay decisions that occurred outside the limitations period." In rejecting Ledbetter's appeal, the Supreme Court said that "she could have, and should have, sued" when the pay decisions were made, instead of waiting beyond the 180-day statutory charging period. The Court did leave open the possibility that a plaintiff could sue beyond the 180-day period if she did not, and could not, have discovered the discrimination earlier. The effect of the Court's holding was reversed by the passage of the Lilly Ledbetter Fair Pay Act in 2009.

In 1979 Lilly Ledbetter, the plaintiff, began work at the Goodyear Tire and Rubber Company in its Gadsden, Alabama location, a union plant. She started with the same pay as male employees, but by retirement, she was earning $3,727 per month compared to 15 men who earned from $4,286 per month (lowest paid man) to $5,236 per month (highest paid man). During her years at the factory as a salaried worker, raises were given and denied based partly on evaluations and recommendations regarding worker performance. From 1979-1981 Ledbetter received a series of negative evaluations, which she later claimed were discriminatory. Although her subsequent evaluations were good, in part as a result of those early negative evaluations, her pay never reached the level of similar male employees. All merit increases had to be substantiated by a formal evaluation. In March 1998, Ledbetter inquired into the possible sexual discrimination of the Goodyear Tire Company. In July she filed formal charges with the Equal Employment Opportunity Commission. In November 1998, after early retirement, Ledbetter sued claiming pay discrimination under Title VII of the Civil Rights Act of 1964 and the Equal Pay Act of 1963. The Supreme Court did not rule on whether this was discrimination, just the statute of limitations to sue.

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