Lilly Ledbetter is the namesake for the Lilly Ledbetter Fair Pay Act of 2009 and the plaintiff in the Supreme Court case Ledbetter v. Goodyear Tire & Rubber Co., Inc. Ledbetter had worked for Goodyear at its plant in Gadsden, Alabama from 1979 until 1998. After filing a complaint with the Equal Employment Opportunity Commission (EEOC), she sued her employer under Title VII, alleging pay discrimination based on gender. Ledbetter alleged that she consistently received poor reviews from her supervisors, and as a result, she was denied salary raises. However, the Supreme Court held that anyone bringing a Title VII action must have first filed a complaint with the EEOC within 180 days (300 days in some jurisdictions) following the alleged discriminatory decision, and that each paycheck issued as a result of those decisions did not extend or restart the limitation period. The Court explained that because Ledbetter had not brought a complaint within the 180-period following the relevant pay decisions, the lawsuit was untimely.
Ultimately, Congress overruled this decision with the Lilly Ledbetter Fair Pay Act of 2009. This legislation loosened the stringent standard set in the Ledbetter case by stating that each paycheck resulting from a discriminatory decision "restarts the clock" for statute of limitations purposes. In other words, the statute of limitations for a discriminatory compensation case begins to run on the last day an employee receives compensation associated with any discriminatory decision or practice. The act was passed out of recognition that employees often do not realize that they are receiving discriminatory pay until well after the 180-day statute of limitations has passed. However, it is worth noting that the act focuses on claims related to discriminatory compensation and other practices affecting compensation but does not extend the time for filing claims related to other discrete discriminatory acts, such as hiring and termination. For example, the Third Circuit has held that the statute of limitations for a Title VII claim for failure to promote was not affected by the act.
See: Noel v. The Boeing Company (2010)
[Last updated in June of 2023 by the Wex Definitions Team]