Deborah E. Rivera
Professor Andrew Carbon
Management 4301
10 June 2014
Case Review # 3:
The Supreme Court of the United States Case of Ledbetter v. Goodyear Tire &
Rubber Company
Over her nineteen-year career at Goodyear Tire, Lilly Ledbetter was consistently given low
rankings in annual performance and salary reviews and low raises relative to other
employees. Ledbetter sued Goodyear for gender discrimination in violation of Title VII of
the Civil Rights Act of 1964, alleging that the company had given her a low salary because
of her gender. A jury found for Ledbetter and awarded her over $3.5 million, which the
district judge later reduced to $360,000. Goodyear appealed, citing a Title VII provision
that requires discrimination complaints to made within 180 days of the employer’s
discriminatory conduct. The jury had examined Ledbetter’s entire career for evidence of
discrimination, but Goodyear argued that the jury should only have considered the one
annual salary review that had occurred within the 180-day limitations period before
Ledbetter’s complaint. The U.S. Court of Appeals for the Eleventh Circuit reversed the
lower court, but without adopting Goodyear’s position entirely. Instead the Circuit Court
ruled that the jury could only examine 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.
The Circuit Court ruled that the fact that Ledbetter was getting a low salary during the 180
days did not justify the evaluation of Goodyear’s decisions over Ledbetter’s entire career.
Instead, only those annual reviews that could have affected Ledbetter’s payment during the
