1.  H.R. 2831 / S. 1843  Signed into law January 29, 2009  Goal is to clarify Title VII goals and enforcement of pay discrimination

2.  Lilly Ledbetter – worked for Goodyear Tire & Rubber Co. in Alabama  Filed complaint with EEOC regarding pay discrimination with male managers  U.S. Supreme court rules in Goodyear’s favor as complaint was not filed within 180 days of pay discrimination action (paycheck accrual rule)

3.  Encourages employers to conceal discriminating conduct until the 180 days have passed  Employers can gain financial windfall if compensation challenges are not made within 180 days  Ignores workplace realities  Confidential pay information  Disparities can increase over time  Employee can be subject to retaliation if they try to resolve issue with employer & not file complaint with EEOC

4.  Each discriminatory paycheck triggers a new claim filing period, rather than the original decision to discriminate  Ensures employees are not penalized over time if they are not aware of pay discrimination  Restores Title VII two year limitation on back pay