In the first appellate-level opinion interpreting the Lilly Ledbetter Fair Pay Act of 2009, the Court of Appeals for the District of Columbia Circuit held in Schuler v. PriceWaterhouseCoopers, LLC, that an employer's denial of a promotion was not a “discriminatory compensation decision or other practice,” within the meaning of the statute. In that case, the plaintiff acknowledged that his claim was untimely prior to the enactment of the Ledbetter Act but argued that the new law extended the statute of limitations and thus revived his claim. The Court rejected this, explaining that the Ledbetter Act was limited to claims of pay discrimination.