Texas Supreme Court Finds That Ledbetter Act Does Not Apply To State Law Claims
Published by Eric A. Welter on November 28, 2012
In Prairie View A&M v. Chatha, Case No. 10-0353, the Texas Supreme Court found that claims under the Texas Commission on Human Rights Act (“TCHRA”) must be brought within 180 days of the date the claimant was informed of the compensation decision. The Court reversed the Court of Appeals finding that the Lilly Ledbetter Act applied […]
In Prairie View A&M v. Chatha, Case No. 10-0353, the Texas Supreme Court found that claims under the Texas Commission on Human Rights Act (“TCHRA”) must be brought within 180 days of the date the claimant was informed of the compensation decision. The Court reversed the Court of Appeals finding that the Lilly Ledbetter Act applied to Texas state law claims. More after the break.
The facts, according to the court’s order, show that Dr. Chatha began her employment with Prarie View A&M University in 1987 as an associate professor. In 2003, she applied for a promotion to full professor. Dr. Chatha was eventually promoted in 2004. At that time, she complained that her salary was inequitable but was told that there were no funds available for a salary adjustment.
Two years later, Dr. Chatha filed a charge of discrimination with the EEOC and Texas Workforce Commission alleging pay discrimination. Under state law, a charge of discrimination must be filed within 180 days of the discriminatory act’s occurrence. Dr. Chatha argued that, under the Ledbetter Act, each subsequent paycheck was a new act of discrimination and therefore her claim was timely. The University, on the other hand, argued that her pay discrimination claim “occurred” when she was advised of the decision, in 2004, and thus her claim was time-barred.
The Houston Court of Appeals held that Dr. Chatha’s claim was timely because the Ledbetter Act applied to pay discrimination claims filed under state law. The Court found that the Ledbetter Act applied because one of the general provisions of the TCHRA was to execute the policies of Title VII. The Court cited TCHRA amendments and two federal district courts opinions had applied the Ledbetter Act to state law claims.
The Supreme Court of Texas reversed the COA. The Supreme Court noted that nothing required it to interpret state law identically with federal law even though the federal and state laws are largely equivalent and have largely been interpreted consistently. Additionally, the Court found no support in the plain language of the statute or its legislative history that the Texas Legislature intended amendments to Title VII be automatically incorporated into the TCHRA. Consequently, the Supreme Court held that the that Ledbetter Act did not apply to TCHRA claims and that pay discrimination claims brought under state law must generally be brought within 180 days of the date the claimant informed of the compensation decision.
A copy of the Texas Supreme Court’s opinion can be found here.Topics: Texas