Vuong v. N.Y. Life Insurance Co.

2009 WL 306391 (2009)

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Vuong v. N.Y. Life Insurance Co.

United States District Court for the Southern District of New York
2009 WL 306391 (2009)

  • Written by Jamie Milne, JD

Facts

Pheng Vuong (plaintiff) sued his former employer, New York Life Insurance Company (company) (defendant), alleging that the company violated Title VII of the Civil Rights Act of 1964 (Title VII) by discriminating against Vuong based on race and national origin. Specifically, the alleged discriminatory acts included the company’s January 1998 decision to appoint Vuong as co-managing partner of the San Francisco office, rather than the sole managing partner, and the company’s February 1998 decision to allocate differing performance-based compensation to Vuong and the other co-managing partner. The company moved for summary judgment, arguing that Vuong’s claims were barred by Title VII’s statute of limitations because Vuong’s August 2002 charge of discrimination with the Equal Employment Opportunity Commission (EEOC) was filed more than 300 days after the alleged discriminatory decisions were made. The company argued that subsequent paychecks based on any discriminatory compensation decision did not constitute an unlawful employment practice and thus did not trigger a new limitations period for the compensation claim.

Rule of Law

Issue

Holding and Reasoning (Griesa, J.)

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Casebooks

Legal Method

Key Terms

  • Title VII of the Civil Rights Act of 1964A federal statute that prohibits employment discrimination on the basis of race, color, religion, sex, or national origin.
  • Summary JudgmentA final ruling that there is no genuine issue of material fact in dispute and that the moving party is entitled to judgment as a matter of law. Summary judgment may also be called summary disposition.
  • Statute of LimitationsA specified period of time, usually prescribed by statute, in which a party has to bring a lawsuit after the party has incurred or sustained injury.
  • Equal Employment Opportunity CommissionThe federal agency charged with enforcing employment discrimination laws.
  • Lilly Ledbetter Fair Pay Act of 2009A federal law passed in 2009 that made it easier for plaintiffs to sue for sex-based compensation discrimination in the workplace by resetting the statute of limitations for lawsuits every time the plaintiff receives a paycheck; a response by Congress to the U.S. Supreme Court's decision in Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007), in which the Court ruled that the statute of limitations was set at the date on which the employer first set compensation.

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