Ledbetter v. Goodyear held that Lilly Ledbetter’s Title VII pay-discrimination claim was untimely because she did not file within the charging period after the pay-setting decisions. Congress later changed the rule through the Lilly Ledbetter Fair Pay Act of 2009.
This case must be taught with the later congressional override. Ledbetter was a Supreme Court interpretation of Title VII timing, not the current complete rule after the 2009 Fair Pay Act.
Does each paycheck affected by a past discriminatory pay decision restart Title VII’s filing period, or must the worker file within the period after the original pay-setting decision?
A Title VII pay-discrimination charge must be filed within the statutory charging period after the allegedly discriminatory pay-setting decision. Later paychecks affected by that past decision did not restart the filing period under the Court’s interpretation of Title VII. Congress later changed this rule through the Lilly Ledbetter Fair Pay Act of 2009.
How the justices lined up in this decision.
The decision showed how procedural deadlines can block discrimination claims even when unequal pay continues. It mattered especially for workers who do not know coworkers’ salaries or cannot discover pay discrimination quickly. The later Fair Pay Act restored a more worker-protective rule by treating each discriminatory paycheck as a new unlawful employment practice for filing purposes.
Justice Alito wrote the Court’s opinion, joined by Chief Justice Roberts and Justices Scalia, Kennedy, and Thomas. Justice Ginsburg dissented, joined by Justices Stevens, Souter, and Breyer.