Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007)
Primary Holding
The time for filing a charge of employment discrimination with the Equal Employment Opportunity Commission (EEOC) begins when the discriminatory act occurs, and a pay-setting decision is considered a "discrete act," thus the period for filing an EEOC charge for pay discrimination claims under Title VII starts at the time of the pay-setting decision.
In the Ledbetter v. Goodyear case, Lilly Ledbetter claimed she was paid less than her male colleagues because of gender discrimination. The Supreme Court ruled that workers must file a complaint about pay discrimination within a certain time frame, starting from when the pay decision is made, not when they first notice the pay difference. This ruling is important for consumers because it sets a strict deadline for filing discrimination claims, which means if someone believes they are being unfairly paid, they need to act quickly to protect their rights.
AI-generated plain-language summary to help you understand this case
In Ledbetter v. Goodyear Tire & Rubber Co., Lilly M. Ledbetter worked at Goodyear's Gadsden, Alabama plant from 1979 until her retirement in 1998. Throughout her employment, her salary was influenced by her supervisors' performance evaluations, which Ledbetter alleged were biased against her due to her sex. In March 1998, she filed a questionnaire with the Equal Employment Opportunity Commission (EEOC) alleging sex discrimination, followed by a formal charge in July of the same year. After retiring in November 1998, she initiated a lawsuit claiming pay discrimination under Title VII of the Civil Rights Act and the Equal Pay Act of 1963. The District Court granted summary judgment to Goodyear on several of Ledbetter's claims, including her Equal Pay Act claim, but allowed her Title VII claim to proceed to trial. During the trial, Ledbetter presented evidence that her pay was adversely affected by discriminatory evaluations, resulting in her earning significantly less than her male counterparts. Although the jury ruled in her favor and awarded backpay and damages, Goodyear appealed, arguing that Ledbetter's claims were time-barred because they were based on pay decisions made before September 26, 1997, which was 180 days prior to her EEOC questionnaire filing. The case reached the Supreme Court on a writ of certiorari after the Eleventh Circuit Court of Appeals reversed the District Court's ruling, stating that Ledbetter's Title VII pay discrimination claim could not include any pay decisions made before the last pay decision affecting her during the EEOC charging period. The Supreme Court ultimately affirmed the Eleventh Circuit's judgment, emphasizing that the time for filing an EEOC charge begins with the occurrence of a discrete act of discrimination, such as a pay-setting decision.
Whether a Title VII pay discrimination claim can be based on pay decisions that occurred outside the 180-day filing period established by the Equal Employment Opportunity Commission (EEOC) when those decisions are part of a continuing violation affecting the employee's pay.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 27, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Alito
- Damages Awarded
- N/A
- Data Quality
- high
Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006)
Consumer WonThe anti-retaliation provision of Title VII of the Civil Rights Act of 1964 protects employees from employer actions that would dissuade a reasonable worker from making or supporting a charge of discrimination, and it is not limited to actions that affect the terms and conditions of employment or occur at the workplace.
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006)
Consumer WonThe numerical threshold of having "fifteen or more employees" in Title VII's definition of "employer" does not affect federal-court subject-matter jurisdiction but instead relates to the substantive adequacy of a Title VII claim for relief, and thus cannot be raised as a defense late in the litigation.
Jackson v. Birmingham Bd. of Ed., 544 U.S. 167 (2005)
Consumer WonTitle IX of the Education Amendments of 1972 encompasses claims of retaliation against individuals who complain about sex discrimination in educational programs, thereby allowing for a private right of action in such cases.
Smith v. City of Jackson, 544 U.S. 228 (2005)
Consumer LostThe Age Discrimination in Employment Act (ADEA) allows for recovery under a "disparate-impact" theory of discrimination, similar to that established in Griggs v. Duke Power Co., but the plaintiffs must still demonstrate a valid disparate-impact claim to succeed.