Ledbetter Vs. Goodyear Tire Case Study
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.
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 …show more content…
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
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 …show more content…
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