Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618, 127 S. Ct. 2162 (2007)

Lilly Ledbetter was employed by Goodyear for approximately 19 years at the company’s Gadsden, Alabama plant. After taking early retirement, Ledbetter commenced this action against Goodyear in which she alleged pay discrimination on the basis of gender in violation of Title VII and the Equal Pay Act. Goodyear asserted that Ledbetter’s pay discrimination claim was time barred with respect to all pay decisions that were made prior to 180 days before she filed her EEOC questionnaire. In order to resolve a conflict among the Courts of Appeals, the Supreme Court granted certiorari and ruled in a 5-to-4 decision that Ledbetter’s claims were subject to a 180-day statute of limitations. The Court concluded that “Ledbetter should have filed an EEOC charge within 180 days after each allegedly discriminatory pay decision was made and communicated to her.” Compare McDonald v. Antelope Valley Cmty. Coll. Dist., 2007 WL 1575511 (Cal. Ct. App. 2007) (equitable tolling principles prevented application of the one-year limitations period of Cal. Gov’t Code § 12960(d)).