Ledbetter Ruling Backs Principal’s Sex-Bias, Equal-Pay Suit

By Mark Walsh — October 29, 2015 2 min read
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An Arkansas elementary school principal’s sex-discrimination and equal-pay lawsuit against her employer may proceed, thanks to the Lily Ledbetter Fair Pay Act of 2009, a federal judge has ruled.

Roxanna Holt alleges in her suit that the discrimination began in 2004 when the Deer, Ark., school district merged with the Mt. Judea district. Holt says that since that time, she has been paid less than a male elementary school principal of similar experience.

Holt has made $57,054 a year for the last five years, while the male principal, Junior Edgmon, earns $64,800, court papers say. Two other male principals are paid the same as her, but have less experience.

Holt also contends that Edgmon has a secretary while she does not, and that she must teach and administer an environmental class, while Edgmon does not. She sued the district after her complaints were met with inaction.

The Deer-Mt. Judea district denies any discrimination. It sought to dismiss Holt’s sex discrimination claim under Title VII of the Civil Rights Act of 1964 and her claim under the Equal Pay Act of 1963 as barred by time because the alleged discriminatory conduct occurred years before Holt filed her claims with the Equal Employment Opportunity Commission.

But Holt relies on the “paycheck rule,” which says that each salary payment based on gender-based pay disparities resets the 180-day clock for filing a discrimination claim.

The paycheck rule was rejected as the proper interpretation of Title VII by the U.S. Supreme Court in its 2007 ruling in Ledbetter v. Goodyear Tire & Rubber Co. But in 2009, soon after President Barack Obama took office, Congress superseded the Supreme Court’s decision with the Lilly Ledbetter Fair Pay Act, which restored the paycheck rule and made it retroactive to the day before the Supreme Court’s decision.

The Deer-Mt. Judea district argued that Holt’s discrimination claims were still barred because the Supreme Court’s Ledbetter decision constituted the meaning of the law before prior to the day of the decision.

In a decision last month in Holt v. Deer-Mt. Judea School District, U.S. District Judge Timothy L. Brooks of Fayetteville said the school district’s view of the law is incorrect.

“Congress’ purpose in passing the [Ledbetter Fair Pay Act] was to nullify the Ledbetter decision and to reinstate the law regarding timeliness of pay compensation claims as it was prior to the Ledbetter decision.

“Congress clearly intends Title VII of the Civil Rights Act to include the paycheck rule, regardless of whether the initial alleged discriminatory decision(s) occurred before or after May 28, 2007,” Brooks said in the Sept. 23 ruling.

Holt’s suit includes some other claims not addressed in the Sept. 23 decision, but Brooks’ ruling gives the female principal’s lawsuit a big boost.

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A version of this news article first appeared in The School Law Blog.