In a recent decision, the United States Court of Appeals for the District of Columbia Circuit became the first federal appellate court to directly address the application of the Lilly Ledbetter Fair Pay Act of 2009, 42 U.S.C. § 2000e-5(e)(3)(A) (“Ledbetter Act”) to promotion denial claims. In Schuler v. PricewaterhouseCoopers, LLP, No. 1:02-cv-00982 (D.C. Cir. Feb. 16, 2010), the court considered whether the Ledbetter Act, which reversed the Supreme Court’s opinion in Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007), should be interpreted to permit a plaintiff to bring a failure-to-promote claim long after he or she originally learned of the promotion denial.