Ledbetter v. Goodyear Tire and Rubber Company (2006)
- Docket
- 05-1074
- Decided
- 2006-01-01
Summary
Question: Can a plaintiff bring a salary discrimination suit under Title VII of the Civil Rights Act of 1964 when the disparate pay is received during the 180-day statutory limitations period, but is the result of discriminatory pay decisions that occurred outside the limitations period? Conclusion: No. By a 5-4 vote the Court ruled that Ledbetter's claim was time-barred by Title VII's limitations period. The opinion by Justice Samuel Alito held that "current effects alone cannot breathe life into prior, uncharged discrimination." For a timely claim, Ledbetter would have needed to file within 180 days of a discriminatory salary decision; the Court did not consider it significant that paychecks she received during the 180 days prior to her claim were affected by the past discrimination. Discriminatory intent is a crucial element of a Title VII disparate-treatment claim, the Court held, but each instance of Goodyear's discriminatory intent fell outside the limitations period. The majority noted that the short time limit was enacted to ensure quick resolution of pay discrimination disputes, which can become more difficult to defend against as time passes. To adopt Ledbetter's argument would be to allow even "discriminatory pay decision[s] made 20 years ago" to be the subject of Title VII claims. In dissent, Justice Ruth Bader Ginsburg called the majority's ruling out of tune with the realities of wage discrimination and "a cramped interpretation of Title VII, incompatible with the statute's broad remedial purpose." She suggested that "the Legislature may act to correct this Court's parsimonious reading of Title VII."