Facts: Lilly Ledbetter worked for Goodyear Tire and Rubber Company’s in Gadsden, Alabama for nineteen years. For most years, she worked as an area manager, which was one, held primarily by men. In the beginning, Ledbetter’s salary stayed similar with the men whom performed similar work. Throughout time, her pay was less than the males pay whom held equal or lower seniority area manager positions. During 1997, Ledbetter’s salary was approximately fifteen percent lower than the lowest paid male Area Manager and about forty percent lower than the highest paid male Area Manager. Ledbetter was subjected to end of year evaluations of their performance performed by their supervisors’. The supervisor evaluated the salaried employee’s performance, ranked the performance against that of other salaried employees, and then recommended a salary increase within a range established by Goodyear guidelines. Having a good, evaluation resulted in a pay increase. Ledbetter was ranked between 1992 and 1997 near the bottom of the other Area Managers. She was awarded either a modest raise or no raise each year. In November 1998, Ledbetter filed a Questionnaire under Title VII of the Civil Rights Act of 1964 with the Equal Employment Opportunity Commission. A formal charge of discrimination claiming, “She had received a discriminatory low salary as an Area Manager because of her sex.”
Issue: Can a plaintiff bring an action under Title VII of the Civil Rights Act of 1964 claiming illegal pay discrimination outside of the 180-day statutory limitation period when the disparate pay was received within the limitation period.
Rule: Title VII of the Civil Rights Act of 1964 states it is unlawful for an employer to discriminate against race, color, religion, sex or national origin. Under Title VII of the Civil Rights Act of 1964, the employee whom has be subjected to the discrimination must first file a charge with the EEOC within the specified time period of 180 or 300 days. (Depending on the state).
Analysis: in July of 1998, Ledbetter filed a suit against Goodyear in the United States District Court for the Northern District of Alabama. In the suit, Ledbetter claimed unlawful salary practices due to discrimination, which occurred within the 180-day statutory period included as a prevision to the Civil Rights Act of 1964. Evidence was presented in an attempt to show that she received the same salary as other males holding the same position. However, by 1998 there was a significant difference in pay. Ledbetter also presented evidence of the person over control of salary displayed “discriminatory animus towards women”. Goodyear stated that the evaluations had been nondiscriminatory, but the jury found for Ledbetter, awarding back pay and damages. Goodyear appealed the District Court decision under the grounds that the pay discrimination claim was time barred with regard to all pay decisions made before September 26, 1997--180 days before Ledbetter filed her EEOC questionnaire--and that no discriminatory act relating to her pay occurred after that date. The Eleventh Circuit reversed the District Courts decision. Holding that a Title VII pay discrimination claim cannot be based on allegedly discriminatory events that occurred before the last pay decision that affected the employee's pay during the EEOC charging period, and concluding that there was insufficient evidence to prove that Goodyear had acted with discriminatory intent in making the only two pay decisions during that period, denials of raises in 1997 and 1998.
Conclusion: The United States Supreme Court affirm the judgment of the Court of Appeals. Stating that the “petitioner must identify with care the specific employment practice that is at issue”. Ledbetter points to two different possible candidates of unlawful employment discrimination. First that the paychecks that were issued to her during the EEOC charging period (the 180-day period preceding the filing of her EEOC questionnaire), each of which, she contends, was a separate act of discrimination. Alternatively, Ledbetter directs us to the 1998 decision denying her a raise, and she argues that this decision was “unlawful because it carried forward intentionally discriminatory disparities from prior years.” The Supreme Court holds that Both of these arguments fail. Stating that “They would require us in effect to jettison the defining element of the legal claim on which her Title VII recovery was based. Ledbetter’s central claim of disparate treatment was rejected by the Supreme Court. The Supreme Court proclaim that “a disparate-treatment claim comprises two elements: an employment practice, and discriminatory intent. Nothing in Title VII supports treating the intent element of Ledbetter’s claim any differently from the employment practice element. If anything, concerns regarding stale claims weigh more heavily with respect to proof of the intent associated with employment practices than with the practices themselves”. Ledbetter’s policy arguments for giving special treatment to pay claims find no support in the statute and are inconsistent with our precedents. The Supreme Court have apply that any unlawful employment practice, including those involving compensation, must be presented to the EEOC within the period prescribed by statute. Ledbetter’s claim was untimely. Therefore, the Supreme Court Affirm the Court of Appeals for the Eleventh Circuit.