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Supreme Court limits gender pay discrimination lawsuits

[JURIST] The US Supreme Court [official website; JURIST news archive] ruled Tuesday that an employee cannot bring a lawsuit for pay discrimination under Title VII of the Civil Rights Act of 1964 [text] 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. [Duke Law case backgrounder; JURIST report], 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 [opinion, PDF], 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) [official website] 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 [text] per Justice Alito, along with a dissent [text] from Justice Ginsburg. AP has more.

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Paper Chase is JURIST's real-time legal news service, powered by a team of 30 law student reporters and editors led by law professor Bernard Hibbitts at the University of Pittsburgh School of Law. As an educational service, Paper Chase is dedicated to presenting important legal news and materials rapidly, objectively and intelligibly in an accessible format.

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