Determined the right of an employee to sue her employer for pay discrimination if she does not bring her claim within 180 days of her employer's pay decision.
In this case, The Supreme Court ruled that an employee loses her right to sue for pay discrimination if she does not bring her claim within 180 days of her employer's pay decision even if the employee has no reason to believe that that decision is discriminatory. The Court specifically refused to adopt the legal standard urged by the U.S. Equal Employment Opportunity Commission (EEOC) and in the amicus brief submitted by a coalition of employees' and women's rights groups, including Legal Momentum: that each unequal paycheck "starts the clock" for a new discrimination claim.
Lilly Ledbetter worked in Goodyear's Gasden, Alabama tire manufacturing plant for nearly twenty years, holding various managerial positions and receiving regular raises. But after failing to receive a raise for three straight years in the late 1990s, and receiving an anonymous note at work alerting her that her male colleagues were better paid than she, Ledbetter filed a lawsuit. She claimed that by the end of her last year with the company, she made approximately $15,000 less than the lowest-paid male employee with the same job title. After considering that disparity, along with evidence spanning Ledbetter's career at Goodyear, a jury found in Ledbetter's favor; she ultimately was awarded $360,000 in back pay and damages. Goodyear filed a motion to vacate the judgment, arguing that Ledbetter should not have been allowed to challenge pay decisions going back so far in time, but the district court denied it. The Eleventh Circuit reversed, and the case proceeded to the Supreme Court.
In a 5-4 vote with Justices Kennedy, Scalia, and Thomas, Roberts and Alito in the majority, the Court found that the 180-day filing deadline in Title VII, the federal law banning employment discrimination, should be interpreted strictly, so as to protect employers from "stale" claims. It rejected Ledbetter's argument that because the victim of pay discrimination suffers its impact every time an artificially depressed paycheck is issued, the date of the paycheck is the appropriate trigger for the 180-day deadline. Instead, the Court ruled, the employer's underlying decision to pay the discriminatory wage is what matters in calculating the filing deadline, just as it is when challenging other kinds of employer decisions, such as decisions to hire, fire, demote, or transfer.
Justice Ginsburg read from the bench an impassioned dissent, in which Justices Breyer, Souter, and Stevens joined, arguing that pay discrimination is not like other kinds of discrimination, because it is exceptionally difficult to detect, and because it often becomes evident only over time "as an employer makes successive pay decisions that push a woman's salary farther and farther behind her male peers." Yet under the majority's standard, she explained, employees who have suffered a very tangible wrong will be left without a remedy, and discrimination will be permitted to continue indefinitely. She explained that the better approach, consistent with Title VII's purpose and the case law interpreting it, is to treat each paycheck that is "infected by discrimination" as a separate violation that starts the 180-day timeline anew.