Today, President Obama signed into law the Lilly Ledbetter Fair Pay Act of 2009.1 The Ledbetter Act is a Congressional response to a 2007 Supreme Court decision, Ledbetter v. Goodyear Tire & Rubber Co., which significantly limited the ability of plaintiffs to recover back pay in certain circumstances.2 Ledbetter arose when, after 19 years of employment with Goodyear Tire & Rubber, Ms. Ledbetter learned that she had been earning substantially less than her male counterparts. She sued, asserting a disparate pay claim under Title VII of the Civil Rights Act of 1964. The Supreme Court held that the statute-of-limitations period began to run on the day compensation is first set, not on the day of the most recent paycheck as the plaintiff had argued. As a result, the Supreme Court found that the 180-day statute of limitations applicable to Title VII claims barred Ms. Ledbetter’s claim in full.

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