Ledbetter v. Goodyear Tire & Rubber Co.

Lilly Ledbetter (plaintiff) worked for Goodyear Tire & Rubber Company (Goodyear) (defendant) from 1979 until 1998. During Ledbetter’s employment, pay for salaried employees like Ledbetter was based on supervisors’ evaluations of their performance. There was no evidence that Goodyear’s pay structure was adopted to discriminate based on sex. In 1998, Ledbetter filed a sex-discrimination charge against Goodyear with the Equal Employment Opportunity Commission (EEOC). Ledbetter then sued Goodyear in federal district court, alleging claims including pay discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII). Ledbetter asserted that her supervisors gave her poor performance evaluations because of her sex. Ledbetter further asserted that past pay decisions continued to affect her pay amount throughout her employment and that by the end of her employment, she was making significantly less than her male colleagues. A jury found for Ledbetter and awarded backpay and damages. However, the appellate court reversed, holding that a Title VII pay-discrimination claim could not be based on any pay decision that occurred outside the statutorily mandated 180-day period for filing an EEOC charge based on an allegedly unlawful employment practice. The appellate court concluded that there was insufficient evidence that Goodyear acted with discriminatory intent in making decisions about Ledbetter’s pay during the 180-day period. Ledbetter petitioned the United States Supreme Court for certiorari on the narrow issue of whether an employee could bring a Title VII pay-discrimination action if the employee received disparate pay during the statutorily mandated filing period but the disparate pay resulted from intentionally discriminatory pay decisions made outside the filing period. The Supreme Court granted Ledbetter’s certiorari petition.