JURIST - Paper Chase: Supreme Court limits gender pay discrimination lawsuits

[JURIST] The US Supreme Court [official website; JURIST news archive] ruled Tuesday that an employee cannot bring a lawsuit for pay discrimination under Title VII of the Civil Rights Act of 1964 [text] for allegedly discriminatory actions that occurred outside the statutory limitations period even when a paycheck is received during the statutory limitations period. In Ledbetter v. Goodyear Tire & Rubber Co. [Duke Law case backgrounder; JURIST report], Lilly Ledbetter, who worked at Goodyear for 19 years, alleged that she received less pay than male counterparts because of sex discrimination. The district court awarded Ledbetter $360,000 in damages but the US Court of Appeals for the Eleventh Circuit reversed [opinion, PDF], holding that the district court should have granted Goodyear's motion for judgment as a matter of law because the statute required Ledbetter to file her complaint with the Equal Employment Opportunity Commission (EEOC) [official website] within six months of the alleged illegal employment practice.

The Supreme Court affirmed the federal appeals court, rejecting Ledbetter's argument that each paycheck issued violated Title VII, triggering a new six-month EEOC filing period. The Court held that "a pay-setting decision is a discrete act that occurs at a particular point in time" and that the statutory period for filing an EEOC claim begins when that discrete act occurs. Read the Court's 5-4 opinion [text] per Justice Alito, along with a dissent [text] from Justice Ginsburg. AP has more.

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