Ledbetter v. Goodyear Tire & Rubber Co.
2007 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007), is an employment discrimination decision of the Supreme Court of the United States.[1] 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 it was affected by a prior decision outside the time limit. Ledbetter's claim of the “paycheck accrual rule” was rejected.[2] 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,[3] or 42 U.S.C. 1981, which has a four-year deadline for suing over race discrimination.[4]
Ledbetter v. Goodyear Tire & Rubber Co | |
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Argued November 27, 2006 Decided May 29, 2007 | |
Full case name | Ledbetter v. Goodyear Tire & Rubber Co., Inc. |
Docket no. | 05-1074 |
Citations | 550 U.S. 618 (more) 127 S. Ct. 2162; 167 L. Ed. 2d 982; 2007 U.S. LEXIS 6295; 75 U.S.L.W. 4359 |
Case history | |
Prior | Judgment for Plaintiff, (N.D. Ala.); rev'd, 421 F.3d 1169 (11th Cir. 2005), cert granted, 548 U.S. 903 (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 | |
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Case opinions | |
Majority | Alito, joined by Roberts, Scalia, Kennedy, Thomas |
Dissent | Ginsburg, joined by Stevens, Souter, Breyer |
Laws applied | |
Title VII of the Civil Rights Act of 1964 Equal Pay Act of 1963 | |
Superseded by | |
Lilly Ledbetter Fair Pay Act of 2009 |
This was a case of statutory rather than constitutional interpretation, explaining the meaning of a law, not deciding 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.[5] The effect of the Court's holding was reversed by the passage of the Lilly Ledbetter Fair Pay Act in 2009.