## Facts

- Lilly M. Ledbetter worked for Goodyear for about nineteen years as a salaried supervisor at its Gadsden, Alabama plant.
- Raises for salaried employees were typically determined through annual performance evaluations and related pay-setting decisions.
- Ledbetter alleged that certain supervisors gave her discriminatory evaluations because of her sex, causing her pay to lag behind male coworkers doing substantially similar work.
- In 1998, Ledbetter submitted an EEOC questionnaire and later filed a formal EEOC charge; she retired later that year.
- Ledbetter sued in federal court, including a Title VII sex-based pay discrimination claim.
- A jury found for Ledbetter and awarded substantial damages; the district court reduced the award to comply with statutory caps.
- The Eleventh Circuit reversed, concluding the claim was untimely and that the relevant pay decisions within the charging period lacked sufficient proof of discriminatory intent.

## Issues

1. Under Title VII, does the 180-day EEOC charge-filing period for pay discrimination run from each paycheck reflecting past discrimination, or from the employer’s discrete pay-setting decisions?
2. Can a plaintiff rely on pay disparities within the limitations period when the allegedly discriminatory pay decisions occurred outside the limitations period?

## Decision

- The Supreme Court affirmed the Eleventh Circuit in a 5–4 decision (Justice Alito).
- The Court held Ledbetter’s Title VII pay discrimination claim was time-barred.
- The limitations period is triggered by a discrete discriminatory compensation decision, not by later paychecks that merely implement that decision’s effects.
- Because the allegedly discriminatory pay-setting decisions occurred outside the 180-day window, and the decisions within the window were not shown to be intentionally discriminatory, Ledbetter could not recover under Title VII on this theory.

## Legal Principles

- Title VII requires an EEOC charge within 180 days “after the alleged unlawful employment practice occurred,” focusing on the specific employment practice challenged.
- A discrete pay-setting decision (e.g., setting salary, granting or denying a raise) is the actionable event; later paychecks that reflect past decisions are continuing effects, not new unlawful practices.
- Subsequent non-discriminatory acts that carry forward adverse effects from untimely discrimination do not restart the charge-filing period.
- Hostile work environment claims may involve a series of acts constituting one unlawful practice; the same approach does not generally apply to discrete compensation decisions.
- Other statutory schemes (e.g., the Equal Pay Act) may have different limitations rules and procedural requirements than Title VII.

## Conclusion

The Court held that Title VII’s administrative filing period for compensation discrimination runs from the employer’s discrete pay-setting decisions, and that later paychecks reflecting the ongoing effects of earlier, unchallenged discrimination do not restart the time to file an EEOC charge.


Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007)