Article on Schuler v. PwC - D.C. Circuit speaks to Ledbetter Act

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On February 16, 2010, the United States Court of Appeals for the D.C. Circuit decided Schuler v. PricewaterhouseCoopers, LLP. In an opinion written by Judge Douglas Ginsburg, the D.C. Circuit affirmed a grant of summary judgment to PricewaterhouseCoopers on the plaintiffs’ claims under the Age Discrimination in Employment Act of 1967 and District of Columbia Human Rights Law and reversed the district court’s grant of summary judgment as to claims under the New York State Human Rights Law. Schuler is significant as it is the first Circuit Court of Appeals decision to construe the scope of the Lilly Ledbetter Fair Pay Act of 2009. In doing so in a narrow fashion, the D.C. Circuit held that an employer’s denial of a promotion is not a “discriminatory compensation decision” or “other practice” within the meaning of the Act.

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