Ledbetter v. Goodyear
| Ledbetter v. Goodyear Tire & Rubber Co | ||||||||||||
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| Argued November 27, 2006 Decided May 29, 2007 |
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| Holding | ||||||||||||
| The EEOC 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. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: John Roberts Associate Justices: John Paul Stevens, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito |
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| Case opinions | ||||||||||||
| Majority by: Alito Joined by: Roberts, Scalia, Kennedy, Thomas Dissent by: Ginsburg Joined by: Stevens, Souter, Breyer |
Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. ___ (2007), is an employment discrimination decision of the Supreme Court of the United States. Justice Alito held for the five-justice majority that employers are protected from lawsuits over race or gender pay discrimination if the claims are based on decisions made by the employer 180 days ago or more.
Facts
In 1979 Lilly Ledbetter, the plaintiff, began work at the Goodyear Tire and Rubber Company in its Gadsden, Alabama location. During her years at the factory, raises were given and denied based on evaluations and recommendations regarding worker performance. In March 1998, Ledbetter inquired into the possible sexual discrimination of the Goodyear Tire Company. In July she filed formal charges with the EEOC. In November 1998, after early retirement, Ledbetter sued claiming pay discrimination under Title VII of the Civil Rights Act of 1964 and the Equal Pay Act of 1963.
Procedural History
The District Court found in favor of Goodyear on the Equal Pay Act claim, because that Act allows pay differences that are based on merit. The court allowed the Title VII and other claims to proceed to trial. Ledbetter claimed that she had been evaluated unfairly because of her gender and therefore had been paid significantly less than her male colleagues. Goodyear claimed their evaluations were non-discriminatory and only focused on worker competence. The jury found for Ledbetter and awarded back pay and damages. Goodyear appealed, arguing that all claims to damages before September 26 1997 were void due to the statute of limitations placed on discrimination claims.
The United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision stating that Ledbetter could only sue for allegations regarding pay decisions that occurred less than 180 days before her beginning the EEOC process in March of 1998. Ledbetter, as the court ruled, could not sue on decisions that merely affected pay in the 180 day period. Furthermore, all decisions made concerning pay in the 180 day period could not be unequivocally linked to her gender. Ledbetter sought a writ of certiorari, but did not contest the sufficiency of the evidence concerning decisions in the 180 day period. The Supreme Court granted the writ and heard the appeal.
Holding
Justice Alito delivered the opinion of the court. The Court held that according to Title VII, discriminatory intent must be a central element in the 180-day charging period. Ledbetter did not claim that Goodyear acted with discriminatory intent in the charging period, in issuing the checks, or denying her a raise in 1998. She argued that the discriminatory act occurred long before and affected her in the charging period. Prior caselaw, the Court held, established that the actual act of intentional discrimination must occur within the charging period. The Court also stated that according to these cases, Ledbetter’s claim that each check is an act of discrimination is inconsistent with the statute because there was no evidence of discriminatory intent in the issuing of the checks.
Dissent
Justice Ginsburg dissented from the opinion of the Court.[1] She argued that the 180-day limit could not apply to pay discrimination, because discrimination often occurs in small increments over large periods of time. Furthermore, the pay information of fellow workers is typically confidential and unavailable for comparison. Ginsburg argued that pay discrimination is inherently different from adverse actions, such as termination. Adverse actions are obvious, but small pay discrepancy is often difficult to recognize until more than 180 days of the pay change. Ginsburg argued instead that Goodyear had created a hostile work environment, and therefore could be charged with acts outside the 180-day charging period.
Notes and references
- ^ "Over Ginsburg's Dissent, Court Limits Bias Suits" by Robert Barnes, The Washington Post, May 30, 2007
External links
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