In a favorable decision for employers, the U.S. Supreme Court held that an employee's Title VII claim for sex discrimination – based on allegations of unequal pay compared to her male peers - was untimely because she waited several years following the allegedly discriminatory acts to bring her claim. In Ledbetter v. Goodyear Tire & Rubber Company, the employee, Ms. Ledbetter, worked from 1979 until 1998 when she retired and brought suit. Ledbetter alleged that, several years prior to her separation, Goodyear supervisors gave her poor performance evaluations because of her sex. Purportedly as a result, Goodyear did not increase her pay as much as it would have if supervisors had evaluated her in a nondiscriminatory manner. By the time of her retirement, Ledbetter's compensation differed substantially from her male coworkers.
To bring a viable Title VII claim in the courts, Ledbetter was first required to file an EEOC charge of discrimination within 180 days of the applicable discriminatory acts. There was no dispute that Ledbetter filed her EEOC Charge more than 180 days after the allegedly discriminatory performance decisions by her supervisors; indeed, she filed her charge several years after those decisions. However, Ledbetter urged that each pay check during the last year of her employment gave present effect to past discrimination and was therefore actionable discrimination. A jury agreed and awarded her back pay and other damages. On appeal, the court rejected Ledbetter's argument, holding that because Title VII requires a showing of intentional discrimination, an employee is required to bring suit within the statutory period immediately after the intentional discriminatory act. As Ledbetter presented no evidence of intentional discriminatory actions within the limitations period, her claim arising out of past discriminatory acts was untimely.
The court noted that a different outcome may occur with federal Equal Pay Act ("EPA") claims arising from the same fact pattern. The EPA, which prohibits compensation discrimination based on gender, does not require proof of an intent to discriminate.