INTRODUCTION
In Ledbetter v. Goodyear Tire & Rubber Co., the Supreme Court held that an employee was barred from suing her employer for pay discrimination under Title VII. (1) The plaintiff, Lilly Ledbetter, was a twenty-year employee of Goodyear who, over the course of her employment, repeatedly received lower raises than her male counterparts because supervisors had given her negative evaluations due to her sex. (2) By the end of her employment at Goodyear, Ledbetter's salary was significantly lower than those of any of her male peers. (3) The Supreme Court, however, held that Ledbetter could not recover because she failed to comply with the Equal Employment Opportunity ...