SUMMARY
Lilly Ledbetter was an employee at the Goodyear Tire and Rubber Co. plant in Alabama. She was the only female production supervisor and after an involuntary transfer to a less-desirable job and discovery of inequitable pay, she took an early retirement. Ledbetter filed an employment discrimination charge with the EEOC, alleging discrimination in pay and performance evaluations on the basis of her sex.
QUESTIONS PRESENTED
Under Title VII of the Civil Rights Act, should pay discrimination claims be treated as discriminatory firing or as hostile environment claims and when does the 180-day time limit for filing a pay discrimination claim begin?
BRIEF ANSWER
In this case, the U.S. Supreme…show more content… However, in prior cases, the Court upheld such claims as hostile environment claims, resetting them at every discriminatory incident.
FACTS
Six months prior to leaving the company for early retirement, Lilly Ledbetter filed these employment discrimination alleging discriminatory pay and seniority procedures. When the case was tried in district court, a jury found the allegations against Goodyear Tire & Rubber Co. to be true and awarded Ledbetter over $3.6 million in punitive damages, which the district court later reduced to $360,000, as per the damage cap provisions of Title VII of the Civil Rights Act. Goodyear appealed this decision saying her filing of these discriminatory actions was not within the statute of limitations…show more content… In the end, the Supreme Court sided with Goodyear Tire & Rubber Co. This ruling, however, contradicted the precedent set by the National Railroad Passenger Corporation (Amtrak) v. Morgan case a few years prior. That case ruled that acts of discrimination must be challenged within 180 days of their occurrence, but the clock would reset upon each incident. Had this case been upheld in the way that National Railroad Passenger Corporation (Amtrak) v. Morgan was, then the 180-day clock would have been reset for Ledbetter every time she received an inequitable paycheck and there would have been no ambiguity in the case. In case 05-1074, the Court did not view the pay discrimination as a “discrete act,” but rather viewed this pay discrimination as a past discriminatory decision that just happened to result in present discriminatory consequences. Labor activists feel that the way the statute was applied in this case “ignored the realities of both pay discrimination claims, specifically, and workplace bias more generally,” because Ledbetter presented a prima facie employment discrimination case, but in the end was not awarded damages. This is another example of a case, similar to Dukes v. Wal-Mart Stores Inc., were a deep-rooted discrimination issue is dismissed because
