Lilly Ledbetter Fair Pay Act Does Not Save ADA Discrimination Claim: Second Circuit | Practical Law
In Davis v. Bombardier Transportation Holdings (USA) Inc., the US Court of Appeals for the Second Circuit held that the Lilly Ledbetter Fair Pay Act of 2009 applies to traditional pay-discrimination claims involving discriminatory compensation practices but not to discrimination claims in which demotions and other adverse employment actions result in a pay reduction. The Second Circuit found that an employee's time-barred disability discrimination claim was not resurrected by the Ledbetter Act.