Ledbetter v. Goodyear Tire & Rubber Co., Inc.
Ledbetter sued Goodyear for salary discrimination based on gender, a violation of Title VII of the Civil Rights Act of 1964, found in 42 U.S.C. §§ 2000e to 2000e-17. During her nineteen year career at Goodyear, in which Ledbetter worked at various positions, she was frequently given low ranks in her annual performance reviews and consequently received lower raises and less pay than her male coworkers. The jury in district court awarded Ledbetter $3,514,417 in total damages, which the court later reduced to $360,000.
Goodyear moved for a judgment as a matter of law, stating that 42 U.S.C. § 2000e-5(e)(1) requires a person to file a complaint with the Equal Employment Opportunity Commission within 180 days of the alleged illegal employment practice, which would make most of Ledbetter's nineteen year long claim inapplicable. According to Goodyear, the only employment decision that could properly be the focus of Ledbetter's complaint was the annual review that occured within 180 days of her complaint to the EEOC. The district court denied Goodyear's motion but the United States Court of Appeals for the Eleventh Circuit reversed, granting the motion on appeal. The court of appeals held that an employee's complaint can include only the last affirmative action that affected her salary before the 180 day period of limitations. Examining this action, the court determined that no reasonable jury could find that this decision was discriminatorily motivated.
Question Presented:
Whether and under what circumstances a plaintiff may bring an action under Title VII of the Civil Rights Act of 1964 alleging illegal pay discrimination when the disparate pay is received during the statutory limitations period, but is the result of intentionally discriminatory pay decisions that occurred outside the limitations period.
