Pay Discrimination Claims Under Title VII of the Civil Rights Act

A Legal Analysis of the Supreme Court's Decision in Ledbetter v. Goodyear Tire & Rubber Co., Inc.

"This report discusses Ledbetter v. Goodyear Tire & Rubber Co., Inc., a recent case in which the Supreme Court considered the timeliness of a sex discrimination claim filed under Title VII of the Civil Rights Act, which prohibits employment discrimination on the basis of race, color, religion, sex, or national origin. In Ledbetter, the female plaintiff alleged that past sex discrimination had resulted in lower pay increases and that these past pay decisions continued to affect the amount of her pay throughout her employment, resulting in a significant pay disparity between her and her male colleagues by the end of her nearly twenty year career. Under Title VII, a plaintiff is required to file suit within 180 days after an alleged unlawful employment practice has occurred. Although the plaintiff in Ledbetter argued that each paycheck she received constituted a new violation of the statute and therefore reset the clock with regard to filing a claim, the Court rejected this argument, reasoning that even if employees suffer continuing effects from past discrimination, their claims are time barred unless filed within the specified number of days of the original discriminatory act. Currently, several bills that would supercede the Ledbetter decision by amending Title VII have been introduced in the 110th Congress, including H.R. 2660 and H.R. 2831, and a companion bill to H.R. 2831 has been announced for introduction in the Senate." Source: Congressional Research Service

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