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. 3. 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. 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,...
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