Ledbetter v. Goodyear Tire & Rubber Co.

SCOTUSCase
Litigants=Ledbetter v. Goodyear Tire & Rubber Co
ArgueDate=November 27
ArgueYear=2006
DecideDate=May 29
DecideYear=2007
FullName=Ledbetter v. Goodyear Tire & Rubber Co., Inc.
USVol=
USPage=
CitationNew=550 U.S. ___
Prior= "verdict for plaintiff" (N. Dist. Ala.), "reversed", 421 F. 3d 1169 (11th Cir. 2005), "cert granted", 548 U. S. ___ (2006)
Subsequent=
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.
SCOTUS=2006
Majority=Alito
JoinMajority=Roberts, Scalia, Kennedy, Thomas
Dissent=Ginsburg
JoinDissent=Stevens, Souter, Breyer
LawsApplied=

"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.

This was a case of statutory rather than constitutional interpretation. 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.

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.

tatutory provisions

*"It shall be an unlawful employment practice for an employer… to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin...." [ [http://www.law.cornell.edu/uscode/42/usc_sec_42_00002000---e002-.html 42 U.S.C. § 2000e-2(a)(1)] .]

*"A charge under this section shall be filed within one hundred and eighty days after the alleged unlawful employment practice occurred." [ [http://www.law.cornell.edu/uscode/42/usc_sec_42_00002000---e005-.html 42 USC § 2000e–5(e)(1)] .]

*"it shall not be an unlawful employment practice for an employer to apply different standards of compensation...provided that such differences are not the result of an intention to discriminate because of race, color, religion, sex, or national origin." [ [http://www.law.cornell.edu/uscode/42/usc_sec_42_00002000---e002-.html 42 U.S.C. § 2000e-2(h)] .]

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 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 occur during the 180-day charging period. Ledbetter did not claim that Goodyear acted with discriminatory intent in the charging period by issuing the checks, nor by denying her a raise in 1998. She argued that the discriminatory behavior occurred long before but still affected her during the 180-day charging period. Prior caselaw, the Court held, established that the actual intentional discrimination must occur within the charging period. The Court also stated that according to those prior 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, [ [http://www.washingtonpost.com/wp-dyn/content/article/2007/05/29/AR2007052900740.html "Over Ginsburg's Dissent, Court Limits Bias Suits"] by Robert Barnes, "The Washington Post", May 30, 2007] joined by Justices Stevens, Souter, and Breyer. She argued against applying the 180-day limit 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 that the broad remedial purpose of the statute was incompatible with the Court's "cramped" interpretation. Her dissent asserted that the employer had been, "Knowingly carrying past pay discrimination forward" during the 180-day charging period, and therefore could be held liable.

ee also

* List of United States Supreme Court cases, volume 550
* Lilly Ledbetter Fair Pay Act

Notes and references

External links

* [http://www.supremecourtus.gov/opinions/06pdf/05-1074.pdf Text of the Decision] ( [http://www.law.cornell.edu/supct/html/05-1074.ZS.html Html version] )
* [http://www.nytimes.com/2007/05/29/washington/30scotuscnd.html "Justices Limit Discrimination Suits Over Pay"] by Linda Greenhouse, "New York Times", May 29, 2007
* [http://www.oyez.org/cases/2000-2009/2006/2006_05_1074/argument/ Oral Arguments (currently only transcript) before the U.S. Supreme Court] , Oyez.
* [http://www.evendon.net/PublicService/cgi-bin/HandOff-1_0.cgi?SC2006+05-1074_Ledbetter_v_Goodyear_Tire__Rubber_Co+0001#top Supreme Court Opinion in Convenient Form]