Ledbetter Case Brief
Citation Ledbetter v. Goodyear Tire & Rubber Co. , 550 U. S. 618 (2007) Facts 1. Lilly Ledbetter worked as a supervisor for Goodyear Tire & Rubber company in Gadsden, AL for 19 years. Being an employee at this plant required her pay and raises to be determined by performance reviews. She was being paid significantly less than her male coworkers. 2. In March of 1998, Ledbetter submitted a questionnaire to the Equal Employment Opportunity Commission (EEOC) alleging sex discrimination against her employer. In July of 1998, she filed a formal EEOC charge against the company. . After retiring in November of 1998, she began her suit against the company citing a Title VII pay discrimination claim along with a claim under the Equal Pay Act of 1963, 29 U. S. C. § 206(d). Previous history: The district court allowed Ledbetter’s Title VII pay discrimination claim to go to trial. Ledbetter claimed that several supervisors had given her bad evaluations because of her sex. These bad evaluations resulted in Ledbetter being paid less than her male coworkers. The district court ruled in favor of Ledbetter.
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Goodyear requested an appeal arguing that Ledbetter’s claim’s were not made within the statute of limitations (180 days after the last discriminatory act). The United States Court of Appeals for the Eleventh Circuit reversed the district court’s decision. Issues 1. Can Ledbetter bring a salary discrimination suit under the Title VII act if she is being paid during the 180 day statutory limitations period, but claims that the rate of pay is discriminatory because of a pay evaluation made before the statutory limitations period? Rules Ledbetter argues that there is a “paycheck accrual rule”, as noted in Bazemore v.
Friday 448 U. S. 385 (1986). Which means, if a company issues a check that is notably less than a comparable employee’s, it is a discriminatory action against the employee, and causes the statue of limitations to refresh. Judge Alito writes in his opinion, “We have previously held that the time for filing a charge of employment discrimination with the Equal Employment Opportunity Commission(EEOC) begins when the discriminatory act occurs. We have explained that this rule applies to any ‘[d]iscreteac[t]’ of discrimination, including discrimination in ‘termination, failure to promote, denial of transfer, [and]refusal to hire. National Railroad Passenger Corporation v. Morgan, 536 U. S. 101, 114 (2002). ” Application There are a few cases that were analyzed during this proceeding. A few of them are as follows: The judges pointed out that in the case of United Air Lines, Inc. v. Evans, 431 U. S. 553 (1977), which was a similar case with similar allegations, the court stated since Evans didn’t file an EEOC claim within the statute of limitations (after she was terminated) and waited to try filing one after she was rehired as a new employee with a lower wage, the airline did not commit a new discriminatory act.
Therefore, Evan’s claim was denied. Bazemore v. Friday 448 U. S. 385 (1986) is the main case discussed since it is most like the case at hand. The outcome of Bazemore, is that the court ruled in favor of the plaintiff(s) because it was unlawful for the company to pay it’s black employees considerably less than it’s white employees. Each paycheck issued where the blacks where paid less than the whites, meant that it was a new discriminatory act towards the blacks, and that the statue of limitations would begin again and the initial pay decision occurred before Title VII.
This is not a discrete form of discrimination, however it is cumulative, as it is in Ledbetter’s case. However, a person can only file a claim when there is a certain act of discrete discrimination that occurs, and the person must file a claim within the 180 day statutory limitations period. Ledbetter knew she was being paid less but failed to file a complaint or make a claim after her last evaluation. Conclusion The court ruled that Ledbetter’s claim was time-barred by Title VII’s 180 day statutory limitations period.