How does Title VIIs 180-days statute of limitations apply to periodic paychecks alleged to be discriminatory?
Ledbetter v. Goodyear Tire & Rubber (No. 05-1074): Ledbetter claimed her employer paid her a smaller salary than it paid male co-workers because of her sex. Her periodic paychecks were based on annual salary reviews over a period of several years. The 11th Circuit held that her claim was time barred because she could not prove intentional discrimination in either (1) the one decision during the limitations period or (2) the last decision preceding the limitation period. The US Supreme Court will review the 11th Circuit decision during its 2006 Term which begins in October. Decision below: Ledbetter v. Goodyear Tire & Rubber (11th Cir 08/23/2005).
