Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007) (U.S. Supreme Court)
Ledbetter v. Goodyear Tire is a landmark Supreme Court decision on the accrual of Title VII pay discrimination claims.
For a Title VII compensation discrimination claim, does the EEOC charge-filing period run from each paycheck that reflects an alleged discriminatory pay decision, or from the earlier, discrete act of setting compensation when the decision was made and communicated to the employee?
Under Title VII, a plaintiff must file an EEOC charge within 180 days (or 300 days in deferral jurisdictions) "after the alleged unlawful employment practice occurred." 42 U.S.C. § 2000e-5(e)(1). Discrete discriminatory acts—such as termination, failure to promote, denial of transfer, or a compensation-setting decision—occur on the day they happen and must be challenged within the statutory period. See National R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (2002). The mere present effects of a past discriminatory act do not restart the limitations period. Bazemore v. Friday, 478 U.S. 385 (1986), does not treat paychecks as discrete acts where no discriminatory decision occurred within the limitations period.
The Title VII charge-filing period for a pay discrimination claim begins when the employer makes and communicates the discriminatory compensation decision. Later paychecks that simply implement that decision are not new, discrete acts that restart the filing period. Ledbetter's claim was time-barred because she did not file her EEOC charge within 180 days after any discriminatory pay-setting decision.
Ledbetter crystallized the discrete-act accrual rule for Title VII claims, restricting plaintiffs from reviving stale pay discrimination claims based solely on the issuance of later paychecks. The decision immediately impacted litigation strategy, compliance, and human resources practices concerning pay setting and documentation. Equally important, Ledbetter catalyzed the Lilly Ledbetter Fair Pay Act of 2009, which expressly provides that, for compensation discrimination claims under Title VII, the ADA, the ADEA, and the Rehabilitation Act, each paycheck, benefits payment, or other compensation event that reflects a discriminatory decision restarts the charge-filing clock (while limiting back pay to two years). For law students, the case is a foundational study in statutory interpretation, the Morgan discrete-act framework, limits of the continuing violation doctrine, and the dynamic relationship between courts and Congress in shaping employment discrimination law.