Analysis - Are Employers Required to Credit Pre-PDA Pregnancy Leaves When Calculating Retirement?

At issue is whether two laws are broken with onewanted damages. Foundation to the case was the
stone. Title VII of the of the Civil Rights Act of 1964claim that each paycheck after the act of the
and the Pregnancy Discrimination Act (PDA) are bothemployer had been made illegal was a new
being called into question by Howard Lavin andoccurrence of discrimination a claim built upon the ruling
Elizabeth E. DiMichele. In anticipation of the Supremein Bazemore. As a result the Supreme Court ruled that
Courts hearing of the AT&T v Hulteen case inas the pay structure was lawful the later issued
October 2008 six decided cases with outcomes whichchecks did not extend the employees time to file a
could impact or be impacted by the Supreme Courtscomplaint with the Equal Employment Opportunity
ruling have been reviewed. Therefore are companiesCommission (EEOC).
responsible for correcting injurious actions toWith these three cases in mind I feel that when the
employees before there actions were made illegal.Supreme Court ruled in May 18 to rule in favor of
Evans provides an example of adverse impact. WhileAT&T a firm stance had been taking regarding
employed as a flight attendant a female employeepresent remuneration for past wrongs. What
married in contradiction to the company policyhappened was wrong but allowing all those wrong to
forbidding her to do so. After her dismissal policy wascollect damages now would create a precedent with
changed and eventually she was gained her job back.far reaching implications. All of the eligible masses who
Once back to work she realized that the seniorityhave gained protection under the law since 1964 would
system failed to give credit for any of her priorbe due compensation. Greater wrongs have been
service. The court ruled that the historical event had nocommitted in American history without reparation like
present consequence and nothing further could beslavery, taking of Indian land or the contemporary
done as the employee did not report her complaint in atreatment of detainees in Gutamino Bay. With this in
timely manner to the Equal Employment Opportunitymind I begin to wonder when American's will cease to
Commission (EEOC). However a racial discriminationallow past circumstances to dominate the present.
case would find a different outcome.Please don't misunderstand me I do not advocate
Bazemore involved employees of the North Carolinaforgetting the past. It bothers me though that
Agricultural Extension Service seeking past damagesAmerican's demand payment for suffering when that
due to a discriminatory pay system. Similarly this casesuffering was the catalyst for the changed system
is also an example of adverse impact. Having beenthat we enjoy today?
heard nine years later than Evans the Supreme CourtWorks Cited
reversed its stance regarding the awarding ofLavin, Howard S., and Elizabeth E. DiMichele "Are
damages being sought for injurious actions occurringEmployers Required to Credit Pre-PDA Pregnancy
before their outlaw. Once again time would alter theLeaves When Calculating Retirement Benefits?."
interpretation of this decision.Employee Relations Law Journal (00988898) 34.3
Ledbetter involved a female employee arguing that(2008): 105-112. Legal Collection. EBSCO. Web. 15 Oct.
because the past pay system was discriminatory2009.
each paycheck after that time was affected hence431 U.S. 553 (1977)
her current income was not what it would have been478 U.S. 385 (1986)
had the law been changed earlier therefore she127 S. Ct.