Ledbetter v. Goodyear as the Most Problematic Case

Statutory Interpretation Method

First of all, the Ledbetter Court provided no remedy for the Ledbetter party because they problematically applied the statutory interpretation methods. Legislative intent, as a part of it, is a mechanism used by various participants of the justice system to examine and correctly evaluate the purpose of the bill or an act when it is passed. Understanding legislative intent is essential as it determines the way it is going to be used in the justice system in the future. In the case of Ledbetter v. Goodyear, it was interpreted and misapplied. As the court majority of that hearing have stated, the Title VII 180-day time limitation is in place to secure a timely resolution to trials of discrimination that might be hard to defend with time.¹ With that outlook, the examined pays that happened in the recent 180-day period showed no signs of discrimination.

However, gender pay inequality is arguably an offense that is enacted for an extended period and is inadequate to judge as a separate instance without considering a broader context. Ledbetter reported the discrimination within the 180 days from the last paycheck given, meaning that it could still be interpreted as a part of the comprehensive Act of unequal pay in the required time-frame. The legislative intent for Title VII 180-day time restriction is to ensure timeliness of the reaction to discrimination, not to limit it to a specific period.² In the case of Ledbetter, she received a lower salary compared to her male colleagues that performed similar job throughout her whole career. Therefore, discrimination lasted for more than 20 years.³ Consequently, the offense should be treated as a continuous one rather than an act that happened once.

Legal Reasoning

Secondly, Ledbetter is problematic in its legal reasoning because of its incomplete use of all the legal rules that apply to the specific case. Initially, the lawsuit was filed and won by Ledbetter on the legitimate means provided by Title VII. However, appealed by the Goodyear stating that the discrimination reported did not fall into the 180 days, the Court proceeded to examine the gender-based pay discrimination only from the point of Title VII. The Court failed to consider another perspective of this issue from the lens of the Equal Pay Act.⁴ Though similar in context, Title VII is more specific since it examines the discriminatory actions that occurred within 180 days. The Equal Pay Act, in its turn, is broad to address all the pay disparities in general in the time-frame of two years.⁵ If to review the case on the legal means of the Equal Pay Act, Ledbetter’s discrimination would have been subjected to the examination of the past two years instead of 180 days.

Also, unlike the initial court hearing and related lawsuits, the Appeal Court failed to recognize each unequal paycheck as a separate act of inequality. This resulted in a lack of context to the trial.⁶ As noted in Gideon’s Trumpet, “the Supreme Court never speaks with absolute finality when it interprets the Constitution.”⁷ However, it is essential to review all rules that apply to a specific case since the result of the Court’s decision affects not only the litigant but also society. When Porto described the United States v. Butler trial, he noted that the “court decision was the predictable, almost mechanical, result of a judge’s application of an unambiguous rule of law.”⁸ In the lawsuit of Ledbetter, the court decision was mechanical in a way it was made with no regard to the ambiguous nature of law and oversaw prior court decisions.

Impact on Society

At the same time, examining the impact of the outcome on society is essential when considering this case as problematic. Although the appeal court ruled in favor of Goodyear, leaving Ledbetter with no remedy questionable, Ruth Bader Ginsburg from the appeal court expressed dissent opinion. She stated that the majority of the Court failed to see the realities of the gender pay gap. They are, according to the dissent, primarily restricted by “a cramped interpretation of Title VII, incompatible with the statute’s broad remedial purpose.”⁹ She, therefore, suggested the Legislature to enact a change to correct this trial’s reading of Title VII. Regardless of the dissent, no change of the law was made. According to Porto, in a modern Supreme Court, it is frequent for the participants of the Court to support the majority with which they disagree to mediate the consequences.¹⁰ It might be the case that in Ledbetter v. Goodyear, many decided to withdraw from their original opinion and join the majority to avoid the change in Title VII.

The gender pay gap and gender discrimination in the United States is a pressing issue that had appeared in courts long before Title VII appeared in 1964. The decision in Ledbetter v. Goodyear lawsuit might have been an iconic one for shaping the future of judging gender discrimination in the workplace. Similar to Schultz v. Wheaton Glass Co.’s case, the appeal hearing could have resulted in a correction of Title VII. Unlike Ledbetter v. Goodyear, the Court that examined Schultz’s appeal found that even though, according to Title VII, women did not have identical job titles, they were “equal enough.” Thus, it gave the Court enough legal ground to press the issue and state that it was, in fact, gender discrimination.¹¹ This court litigation was a shaping one for the definition of unequal pay and the way it can be brought up in Court in any future claims to defend women. Senator Wheeler said that cases reviewed by the Supreme Court “will have immediate importance far beyond the particular facts and parties involved”.¹² Unfortunately, the Ledbetter v. Goodyear trial’s importance was ignored by providing no remedy for Ledbetter.

In the sense of a positive outcome for the society, Ledbetter v. Goodyear is problematic. It failed to see the connection between the time implications and the effect of gender discrimination over a long time, which resulted in ignoring gender discrimination, yet following Title VII promptly. As Ginsburg pointed out, the 180-day time-frame appears to be a limitation rather than a tool for quick decisions.¹³ Adding changes to the applications of Title VII would have had a positive on society at large by giving a more specific framework for dealing with issues of gender discrimination at the workplace.

Bibliography

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

Lewis, Anthony. Gideon’s Trumpet. Toronto: Random House of Canada Limited, 1964.

Porto, Brian. May It Please The Court. Boca Raton: C.R.C. Press, 2017.

Riccucci, Norma M. “A Major Setback for Pay Equality.” Review of Public Personnel Administration 28, no. 1 (2008): 91–96. Web.

Shultz v. Wheaton Glass Co., 319 F. Supp. 229 (D.N.J. 1970)

Riccucci, Norma M. “A Major Setback for Pay Equality.” Review of Public Personnel Administration 28, no. 1 (2008): 91–96. Web.

Footnotes

1. Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007).
2. Norma Riccucci. “A Major Setback for Pay Equality,” Review of Public Personnel Administration 28, no. 1 (2008): 92. Web.
3. Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007).
4. Riccucci, “A Major Setback for Pay Equality,” 92.
5. See note 4 above.
6. Riccucci, “A Major Setback for Pay Equality,” 92.
7. Anthony Lewis. Gideon’s Trumpet (Toronto: Random House of Canada Limited, 1964), 76.
8. Brian Porto, May It Please The Court (Boca Raton: C.R.C. Press, 2017), 6.
9. Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007).
10. Porto, May It Please the Court, 10.
11. Shultz v. Wheaton Glass Co., 319 F. Supp. 229 (D.N.J. 1970).
12. Lewis, Gideon’s Trumpet, 145.
13. Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007).