Stale Promotion Claims Under the ADEA Not Aided by Ledbetter Act According to Plaintiff
A recent case from the Circuit Court of Appeals for the District of Columbia offers guidance on how courts might apply the provisions of what is commonly known as the Lilly Ledbetter Fair Pay Act of 2009 (Ledbetter Act). The pertinent part of the case, Schuler v. PricewaterhouseCoopers, LLP, No. 08-7115, 2010 WL 522345 (D.C. Cir. Feb. 16, 2010), involved an effort by the plaintiff Harold Schuler (Schuler) to use the Ledbetter Act to revive a claim of discrimination under the Age Discrimination in Employment Act (ADEA) based on Schuler's having been passed over for promotion to partner at PricewaterhouseCoopers (PwC) in 1999 and 2000.