The US Supreme Court’s five to four decision in Ledbetter v. Goodyear Tire & Rubber Co., Inc. resolved a conflict among the courts of appeals regarding the proper application of the statute of limitations to pay discrimination claims arising under Title VII of the Civil Rights Act of 1964. The Ledbetter decision held that petitioner Lilly Ledbetter’s Title VII claim was untimely because she did not file a charge of discrimination with the Equal Employment Opportunity Commission (EEOC) within 180 days of the allegedly discriminatory pay decisions. In reaching this decision, the Supreme Court declined to adopt the “paycheck accrual” rule proposed by Ms. Ledbetter, which would permit each subsequent paycheck she received during her employment to trigger a new period in which she could file a charge with the EEOC, rendering her claim timely.
Although the Ledbetter decision generally is viewed as a victory for employers, the long-term effects remain to be seen. This Workplace Roundup column briefly summarizes the Ledbetter decision and reviews the extent to which courts in certain jurisdictions are deferential to federal law when interpreting state antidiscrimination laws and, thus, whether federal and state courts in those jurisdictions are more or less likely to apply applicable statutes of limitations in accordance with the rule set forth in the Ledbetter decision.