Goodyear prevails in important Supreme Court Title VII decision involving statute of limitations period
Clients Goodyear Tire & Rubber Co., Inc.
Jones Day represented Goodyear Tire & Rubber Co. in a pay discrimination action that resulted in an important decision for employers. The U.S. Supreme Court held on May 29, 2007 that Title VII bars a private plaintiff from bringing an intentional pay discrimination claim challenging pay decisions that occurred outside of the statutory limitations period, even if those decisions continue to have adverse effects on paychecks received during the limitations period.
The petitioner, Lilly Ledbetter, worked for Goodyear for 19 years. During that time, several different managers made discrete annual decisions regarding what merit increase Ledbetter should receive in her salary. Ledbetter filed an EEOC charge, and subsequently a complaint, challenging the cumulative effect of these 19 years of salary determinations and asserting, among other things, an intentional pay discrimination claim under Title VII. The Supreme Court rejected Ledbetter's argument that she could bring an intentional pay discrimination claim under Title VII where the disparate pay was received during Title VII's limitations period, but was the result of allegedly discriminatory pay decisions occurring outside that period.
Justice Alito, writing for the Court, explained that Title VII's limitations period begins to run when "the alleged unlawful employment practice occurred," which, in the case of an intentional pay discrimination claim, means when "each allegedly discriminatory pay decision was made and communicated to" the plaintiff. Ledbetter did not claim before the Supreme Court that intentionally discriminatory conduct occurred during the limitations period, but rather that Goodyear's nondiscriminatory conduct during the limitations period gave present effect to pay decisions made outside of that period. Such "current effects" of past conduct "alone," the Court concluded, "cannot breathe life into prior, uncharged discrimination." The Court stressed the need to "give effect to the statute as enacted" by Congress, including the limitations period included in Title VII, which protects employers against "stale claims" and encourages "the prompt resolution of employment discrimination allegations." In adopting Goodyear's argument and holding that Ledbetter's claim was time-barred, the Court rejected the positions of seven out of nine courts of appeals that had previously considered the application of Title VII's limitations period to intentional pay discrimination claims.
Ledbetter v. Goodyear Tire & Rubber Co., Inc., 550 U.S. 618 (2007)