U.S. SUPREME COURT UPHOLDS STRICT INTERPRETATION OF STATUTE OF LIMITATIONS FOR TITLE VII CLAIMS

Employers had a victory this month when the U.S. Supreme Court ruled that a plaintiff must file her complaint with the EEOC within 180 days (or 300 days in California) after a discrete act of alleged intentional discrimination occurred. In Ledbetter v. Goodyear Tire & Rubber Company, Inc., Ms. Ledbetter claimed that in the past she had received poor evaluations because of her sex. These past decisions resulted in lower pay and continued to affect her salary throughout her employment. The Supreme Court held that even though Ms. Ledbetter continued to feel the “continuing effects of the alleged discrimination” each time she received a paycheck, the actual discriminatory pay decision had occurred many years ago, and thus that decision “is merely an unfortunate event in history which has no present legal consequences.” The Court pointed out that Ms. Ledbetter “should have filed an EEOC charge within 180 days after each allegedly discriminatory pay decision was made and communicated to her.” Employers should expect that efforts will be made to change this ruling in Congress.