After an appeals court only agreed to review the most current pay review, Lilly Ledbetter asked the Supreme Court to look at all of her pay reviews since she was hired at the center in 1979, and if the court sides with Ledbetter it could change how far back pay reviews can be subject to judicial scrutiny, according to a Society for Human Resource Management article.
Ledbetter worked at the Alabama assembly center for 19 years, and according to the petition she consistently received low performance reviews and lower raises than her counterparts. According to SHRM, by the end of 1997, her salary fell below all 15 other tire assembly area managers, with the lowest paid one pulling in $4,286 per month and the highest paid of the 15 bringing in $5,326, or 40% more than Ledbetter’s $3,727 per month salary.
The next year, Ledbetter was transferred to a technology engineering position but her salary remained stagnant. Three months later, Ledbetter challenged her transfer by filing a Title VII claim against her employer with the Equal Employment Opportunity Commission. She later tacked on a discrimination claim and took early retirement in November 1998.
A district court dumped the transfer claim but ruled that Ledbetter likely received unequal pay because of her sex, and a jury recommended an award of $233,776 in back pay, $4,662 for mental anguish and $3.2 million in punitive damages.
Goodyear said that Title VII required that an employee file a complaint within 180 days of the conduct in challenge. According to SHRM, the court disgarded Goodyear’s argument but reduced the award to $360,000.
However, the 11 th US Circuit Court of Appeals reversed the district court’s ruling, saying that there must be a cap on how far back pay reviews can be considered, or else there would be no reason for time caps under Title VII.
According to SHRM, the 11th Circuit said that when a system is in place to review an employee’s pay, a court can look no further than the last review to determine if the pay was “unlawfully depressed” (See Ledbetter v. Goodyear Tire and Rubber Co ). The court found that Goodyear had legitimate reasons for passing over Ledbetter for raises.
The Supreme Court already has set limits on how far back discrimination claims may go inNational Railroad Passenger Corp. v. Morgan, in which the court ruled that “A Title VII plaintiff raising claims of discrete discriminatory or retaliatory acts must file his charge within the appropriate 180- or 300-day period, but a charge alleging a hostile work environment will not be time barred if all acts constituting the claim are part of the same unlawful practice and at least one act falls within the filing period; in neither instance is a court precluded from applying equitable doctrines that may toll or limit the time period.”