The US Supreme Court ruled Tuesday that an employee cannot bring a lawsuit for pay discrimination under Title VII of the Civil Rights Act of 1964 for allegedly discriminatory actions that occurred outside the statutory limitations period even when a paycheck is received during the statutory limitations period. In Ledbetter v. Goodyear Tire & Rubber Co., Lilly Ledbetter, who worked at Goodyear for 19 years, alleged that she received less pay than male counterparts because of sex discrimination. The district court awarded Ledbetter $360,000 in damages but the US Court of Appeals for the Eleventh Circuit reversed, holding that the district court should have granted Goodyear's motion for judgment as a matter of law because the statute required Ledbetter to file her complaint with the Equal Employment Opportunity Commission (EEOC) within six months of the alleged illegal employment practice.
The Supreme Court affirmed the federal appeals court, rejecting Ledbetter's argument that each paycheck issued violated Title VII, triggering a new six-month EEOC filing period. The Court held that "a pay-setting decision is a discrete act that occurs at a particular point in time" and that the statutory period for filing an EEOC claim begins when that discrete act occurs. Read the Court's 5-4 opinion per Justice Alito, along with a dissent from Justice Ginsburg.