Diversity And Generational Change: Shifts In The Law

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Lilly M. Ledbetter v. The Goodyear Tire & Rubber Company,

Inc., 550 U.S. 618 (2007)

Supreme Court case that triggered a change in the way that employers need to look at discrimination claims, especially as they relate to compensation. Plaintiff worked for Respondent for 20 years starting in 1979, mostly as a salaried manager. When she retired, Ledbetter was the only female area manager. Through an anonymous tip just before she retired, Ledbetter found out that she was paid less than her male counterparts ($3700 per month vs. $4300–$5200 per month for her male colleagues). Ledbetter filed a Charge of Discrimination with the Equal Employment Opportunity Commission in July 1998 claiming that she received lower performance evaluations because of her gender and as a result was paid a lower salary. Ledbetter would subsequently describe her employment conditions as consisting of acts of sexual harassment (quid pro quo relating to a requested exchange for a favorable performance evaluation), hostile work environment, retaliation (reassignment to a heavy-lifting position), as well as pay differentials. The District Court allowed the case to proceed to trial and the jury found in favor of Ledbetter. The Eleventh Circuit Court of Appeals reversed, "holding that a Title VII pay discrimination claim cannot be based on any pay decision that occurred prior to the last pay decision that affected the employee's pay during the EEOC charging period. 421 F. 3d 1169, 1182-1183 (2005)." Ledbetter at 622-623. The U.S. Supreme Court affirmed the Eleventh Circuit's decision. Held: The...