Research Task#2 – Ledbetter v. Goodyear Tire and Rubber Company, 550 U.S. 618 (2007)
Who was the plaintiff and who was the defendant in the case?
Plaintiff – Ledbetter (The party who initiates a lawsuit)
Defendant – Goodyear Tire and Rubber Company (The party whom a laws suit has been initiated)
Was this a federal or state case? Explain why.
A federal case – Federal court jurisdiction only hear cases in which the United States is a party, cases involving the violation of the Constitution or federal law, crimes on federal land, and bankruptcy cases. The case of Ledbetter v. Goodyear Tire and Rubber Company involved a violation of the United States constitution’s provisions against discrimination at the workplace including Title VII of the Civil Rights Act of 1964 and the Equal Employment Opportunity Commission (EEOC). The violation of the two constitutional clauses makes Ledbetter v. Goodyear Tire and Rubber Company a federal case.
Was this a criminal or civil case? Explain why.
The Ledbetter v. Goodyear Tire and Rubber Company case is a civil case – A civil case is filed by a person or entity against another person or entity. Civil cases involve disputes between people or businesses over money or some injury to personal rights. For this reason, the state is not involved in filing the lawsuit. Ledbetter is the entity that filed a petition against her employer Goodyear Tire and Rubber Company, making it a civil case as Ledbetter feels that she is discriminated against by her employer.
Is this case based off a procedural law or substantive law issue? How do you know?
The Ledbetter v. Goodyear Tire and Rubber Company case is based off a procedural law issue as it involves a set of rules to which the courts in the United States are required to follow in order to decide the outcome of the case. The court needs to consider Title VII of the Civil Rights Act of 1964 and the Equal Employment Opportunity Commission (EEOC) to determine whether Ledbetter’s rights were violated by her employer through delayed pay discrimination.
What were the facts of the case?
Ledbetter had worked for Goodyear Tire and Rubber Company for nineteen years, and during this period, she was constantly given low rankings in the company’s annual performance and salary reviews. Also, she received low raises compared to her colleagues at work. As a result, Ledbetter sued Goodyear Tire and Rubber Company for gender discrimination in violation of Title VII of the Civil Rights Act of 1964, accusing that the company had given her a low salary because she was a female. The jury found Ledbetter’s rights to equal treatment at the workplace were violated and thus awarded her over 3.5 million dollars, which the district judge later reduced to only 360,000 dollars. The company was not satisfied with the ruling, and thus, appealed to the United States Supreme Court, citing a Title VII provision that requires discrimination complaints to be made within 180 days of the employer’s discriminatory conduct. In the first petition, the jury had examined Ledbetter’s entire career for discrimination, but the company argued that the jury should only have to consider the one salary review that had occurred within the specified period of 180 days provided by Title VII of the Civil Rights Act of 1964 before Ledbetter made her complaint.
Having considered the provisions of Title VII, the United States Court of Appeal for the Eleventh Circuit reversed the lower court’s decision, but without adopting Goodyear Tire and Rubber Company’s position entirely. The jury ruled that the court could only evaluate Ledbetter’s career for evidence of discrimination as far back as the last annual salary review before the start of the 180-day limitations period provided by the statute. According to the court, the fact that Ledbetter was getting a low salary during the 180 days did not justify the evaluation of the Goodyear Tire and Rubber Company’s decision over her entire career considering that she had worked for 19 years. Instead, only those annual reviews that would have affected her payment during the 180 days could be evaluated. The circuit court found no evidence of discrimination in Ledbetter’s performance reviews which she claimed to have been gender-discriminated, and so, the circuit court reversed the District Court decision and dismissed Ledbetter’s complaint.
This case involved the statute of limitations. Define the statute of limitations and explain its relevance to this case.
The statute of limitations is a law passed by a legislative body to set the maximum time after an event within which legal proceedings may be initiated. The statute of limitations is relevant to the Ledbetter v. Goodyear Tire and Rubber Company case in that it gives a maximum number of days in which a person can file a lawsuit in pursuit of discrimination in their place of work. For this case, Ledbetter could have made a timely claim if she filed her case within 180 days of a discriminatory salary decision. The court did not consider it significant that the paychecks Ledbetter received during the 180 days prior to her claims were affected by discrimination. Based on the case, the short time limit of 180 days was enacted to ensure that quick resolutions to pay discrimination disputes could be offered, as they may become more difficult to defend against as time passes. Accepting Ledbetter’s claims of discrimination for the past 19 years would allow even discriminatory pay decisions made 20 years ago to be subject to claims of Title VII, which can be difficult to prove.
Difference between a grand jury and petit jury
A grand jury is a group that examines accusations against a person charged with a crime, and if the evidence warrants, the jury makes formal charges on which the accused person is later tried. Since it involves a group of citizens examining accusations, through the grand jury, lay persons have the opportunity to participate in the suspect’s trial. A grand jury does not determine the guilt or innocence of a person. A petit jury on the other hand hears evidence in a trial presented by both the plaintiff and the defendant. After hearing the evidence from both parties during a trial, the petit jury returns a verdict. Since the grand jury does not determine the innocence or guilt of a person, it is the petit jury that upon examining the evidence from both the plaintiff and defendant awarded Ledbetter the 3.5 million dollars back pay and compensatory and punitive damages.
The United States Supreme Court ruling in the Ledbetter v. Goodyear Tire and Rubber Company case
The Supreme Court held that according to Title VII, the discriminatory intent should occur during the 180 days of filing the discriminatory petition. Ledbetter failed to claim that Goodyear Tire and Rubber Company acted with discriminatory intent in the charging period by issuing checks and denying her a pay rise in 1998. According to Ledbetter, her employer’s discriminatory behavior occurred long before but still affected her during the 180-day charging period. However, the court asserted that Ledbetter’s claims of discrimination were inconsistent with Title VII statute as there was no evidence of discriminatory intent, and if it existed, the discriminatory intent fell outside the limitations period, making Ledbetter’s claims invalid. Based on this, the court by a 5-4 vote ruled that Ledbetter’s claim was time-barred by Title VII’s limitations period.
What theory of jurisprudence do you think the Justices followed when deciding this case? Why?
Based on Ledbetter v. Goodyear Tire and Rubber Company’s case, the justice can be assumed to have followed the legal positivism theory of jurisprudence in deciding the case. According to the theory, there is no link between morality and law and insists that laws are created and dictated by how human beings behave socially. Besides, the theory states that the merits of the law are not considered; it might be a bad law by some standards but as long as it is governed by an authority it is still a law. Title VII is a law that stipulates that any case involving discrimination should be filed within a 180-days period to ensure quick resolutions to disputes since they are easy to prove. It would be morally right if the judges took consideration of the 19-year career Ledbetter had at Goodyear Tire and Rubber Company to ascertain the intent of discrimination, and not just within the 180-day period. However, it was Ledbetter’s responsibility to file a lawsuit once she perceived that her pay rights were violated through discrimination, but she did not do it within the 180-period, making her claims hard to prove. Therefore, since Title VII is governed by an authority it is still a law, and it doesn’t have to consider the merits to Ledbetter since allowing her case to be determined in her favor would be like allowing other discrimination cases with more than the 180-day limitations to be subject to Title VII, which would not only be hard to prove but will also make the statute loose relevance.
Do you agree with the court’s decision? Why?
I do not agree with the decision in its entirety in that it denies some people a chance for justice and gives employers an opportunity to continue oppressing their employees. Ledbetter has been an employee in Goodyear Tire for 19 years, and all these years, she had been discriminated against for her pay rise due to her gender. Under the Equal Employment Opportunity Commission (EEOC), employers are prohibited from discriminating against employees based on gender, which means that Goodyear Tire may have succeeded in the case for Title VII 180-day limitations, but still discriminated against Ledbetter based on her gender. Also, the company deliberately reviewed her performance negatively so that they could not offer her a pay rise. The reason behind this is that if she performed poorly, she should not have lasted for 19 years in the company as she would have been fired within the first year of work. While Ledbetter may have been patient and loyal working for the company, she was optimistic that the company could reward her someday and thus she might not have rushed to file a lawsuit to protect the company’s reputation. However, I do uphold the ruling as there is a specified timeline – a 180-day limitation period which a person should file a discriminatory petition, which Ledbetter did not adhere to according to EEOC and Title VII.
Lilly Ledbetter Fair Pay Act of 2009
The Act requires employers to redouble their efforts to ensure that their pay practices are non-discriminatory and to make certain that they keep records required to prove the fairness of the pay decisions. The Lilly Ledbetter Fair Pay Act of 2009 is a public law since it’s something that affects society. The Act seeks to prohibit sex-based wage discrimination between men and women in the same establishment that performs jobs that require substantially equal skill, effort, and responsibility under a similar working environment. Equal pay is a social issue, and thus it affects society, making the Act a public law. I believe that Congress enacted the law to help bridge the gap between men and women pay which has been a major problem in the United States where women have been underpaid.
