Results matching “Ledbetter”

Because everyone knows all suits are meritorious - PointOfLaw Forum

Slate's "BizBox" blogger writes that the Lilly Ledbetter Fair Pay Act "only has the potential to harm" those businesses "who, frankly, deserve to be harmed".

Ledbetter Act to apply to promotion, demotion decisions? - PointOfLaw Forum

If so, it would make for a dramatic expansion of workplace liability; while Michael Fox is concerned the new law will be read that way, Ross Runkel believes it will not.

Around the web, February 9 - PointOfLaw Forum

  • Mississippi: Dickie Scruggs said to plan second guilty plea, this time in Peters-DeLaughter matter [NMC @ Folo]
  • Biden aide Mark Gitenstein, tapped for Office of Legal Policy, is target of latest plaintiff's bar campaign because he's lobbied for the U.S. Chamber [slanted L.A. Times via Drum Major Institute, David Arkush of Public Citizen acting as point person; Gitenstein defended by prominent liberals]
  • Mass tort actions brewing against Merck over Gardasil cervical cancer vaccine? [Burch/Mass Tort Lit Blog]
  • Credit crisis litigation wave enters third year [Kevin LaCroix, D & O Diary]
  • Serve the papers on your way out: Ledbetter legislation likely to offer greatest litigation incentive for employees at brink of retirement [McCormick/Prawfsblawg]
  • Two papers by Robert Leflar on medical malpractice and liability in Japan [TortsProf]

President Obama's executive orders on labor/management - PointOfLaw Forum

President Obama brought labor leaders to the White House again today, following yesterday's signing of the Lilly Ledbetter Fair Pay Act. Today's occasion was the issuing of three executive orders sought by organized labor, as described by CQ Politics:

  • One order requires government contractors to offer jobs to qualified employees when contracts change.
  • Obama also undid a Bush executive order that required employers to post signs informing workers of their right to limit financial support of unions serving as their collective bargaining representatives.
  • A third directive prohibits government contractors from being reimbursed for expenses incurred trying to influence workers on whether to form unions or engage in collective bargaining.

The orders are not online yet at, but we did get them through a legal colleague and posted them at Shopfloor:

The White House tried to make the big deal of the day its announcement of its Middle Class Task Force headed by Vice President Biden. A task force! Talking about green jobs!

Meanwhile, a search for "card check" or "Employee Free Choice Act" turns up no references at So that's good.

UPDATE (6:20 a.m. Saturday): Judging by the metadata of one file, one of the regulations was written by the SEIU's legal counsel, or associate general counsel, Craig Becker -- although he may have gone to work for the Administration. (See this post.) Remember all those headlines from eight years ago along the lines of "White House lets business lobbyists write the law?"

Lilly Ledbetter Fair Pay Act - PointOfLaw Forum

Much of what you think you know about it is wrong, argues Stuart Taylor, Jr. at National Journal. Hans Bader is even more critical of the factual representations being made by many advocates of the law, while Jane Genova wonders whether it's okay to go back 27 years in remembering mistreatment.

As Carter noted the other day, the bill is retroactive, with an effective date of May 28, 2007 (play game first, change rules later!) And, after all, time limits on the right to file lawsuits couldn't really be part of the law's "purpose", could they?

Our coverage of the original Ledbetter suit, the Supreme Court decision in which it resulted, the ensuing controversy, and the newly enacted legislation can be found here.

More: Daniel Schwartz argues that symbolism aside, the new enactment will make less difference than either foes or friends generally seem to realize. George Lenard takes a comprehensive look at the new law. And Prof. Obbie at LawBeat has favorable words for the Stuart Taylor National Journal piece linked above.

"The Mirage of Pay Equity" - PointOfLaw Forum

Diana Furchtgott-Roth on the Ledbetter and Paycheck Fairness bills (via NewMajority). More: Bader, CEI.

The House just voted 250-177 to pass S. 181, the Lilly Ledbetter Fair Pay Act, a mostly partyline vote (roll call here). This is the bill that supporters say is necessary to correct the Supreme Court's reading of discrimination law (Title VI of the Civil Rights Act) in Ledbetter v. Goodyear Tire & Rubber. The bill now goes to President Obama for his signature; the White House over the weekend reiterated his full-bore support for the bill.

By lifting all statutes of limitations on employment discrimination suits, the new law will subject employers to many more speculative discrimination lawsuits. That said, organized labor and the activist grievance industry have been the more vocal supporters. Trial lawyers have mostly stayed quiet, a good move in terms of selling the bill politically.

Note the effective date:


This Act, and the amendments made by this Act, take effect as if enacted on May 28, 2007 and apply to all claims of discrimination in compensation under title VII of the Civil Rights Act of 1964 (42 U.S.C. 2000e et seq.), the Age Discrimination in Employment Act of 1967 (29 U.S.C. 621 et seq.), title I and section 503 of the Americans with Disabilities Act of 1990, and sections 501 and 504 of the Rehabilitation Act of 1973, that are pending on or after that date.

May 28th? The Supreme Court issued its Ledbetter ruling on May 29, 2007, so Lilly Ledbetter's suit was still pending then. So does she get another shot at her lawsuit?

Earlier posts here.

When in doubt, sue -- Senate passes Ledbetter bill - PointOfLaw Forum

The U.S. Senate yesterday passed S. 181, the Lilly Ledbetter Fair Pay Act, sold politically as a limited fix to the U.S. Supreme Court's decision in Ledbetter v. Goodyear Tire & Rubber, disallowing an employee's pay discrimination complaint because she brought it after (years after) the clearly written 180-day statute of limitation expired. The vote was 61-36, with five Republicans voting in support and no Democrats voting in opposition. (Roll call.)

Defeated was an amendment by Sen. Mike Enzi (R-WY) to clarify standing so only the allegedly discriminated employee could bring suit, not just somebody "affected" by the consequences of the discrimination. Table (killed) was an amendment by Sen. Johnny Isakson (R-GA) to limit the law's application to claims resulting from discriminatory compensation decisions that occurred after the act's adoption; the law will now allow the filing of claims years, even decades old. An amendment by Sen. Specter to provide a rule of construction was tabled. And the substitute amendment by Sen. Hutchison (R-TX) was defeated on a partyline-minus-one vote (Snowe being the Republican).

In short, any amendment to limit the opportunities for speculative, excessive and "creative" lawsuits was defeated. Sen. Enzi noted several times the bill was run to the floor without any committee hearings that could have allowed more debate, consensus amendments and some bit of restraint. (Enzi is the ranking Republican on the HELP Committee, chaired by Sen. Kennedy.) The end result is surely a wave of new discrimination lawsuits against employers, increasing the marginal costs of new hires.

President Obama will surely sign the bill. Lilly Ledbetter became a cause celebre for Democrats and organized labor during the campaign, and she joined the President-elect on pre-inaugural train ride to Washington.

P.S. Much was made by Senate supporters of the new, positive tone of the debate. Here's Senator Byron Dorgan recalling the "night of terror" in Occoquan Prison in 1917, when suffragettes were brutally beaten. The point being...

UPDATE (10:30 a.m.): It appears the House will vote on the Senate version of the bill next week, dropping its own version that included the politically problematic Paycheck Fairness Act language, i.e., the stalking horse for comparable worth.

The Senate today continues its debate on S. 181, the Lilly Ledbetter Fair Pay Act, which inspires the most opposition among the business community for its elimination of the statutes of limitations in filing pay discrimination complaints under Title VII of the Civil Rights Act. Instead of requiring a complaint within 180 days of the alleged offense, the time limit is renewed every time the supposed victim receives a paycheck. With those standards, an employee could conceivably file a complaint 20, 30 years after the discrimination supposedly occurred. What business can defend against that?

But there's something equally or even more radical in this legislation, which supporters claim is a limited corrective to the U.S. Supreme Court in Ledbetter v. Goodyear Tire and Rubber. No longer is it only the alleged victim of the discriminatory act who has legal standing, it's anyone who is affected.


Section 706(e) of the Civil Rights Act of 1964 (42 U.S.C. 2000e-5(e)) is amended by adding at the end the following:

`(3)(A) For purposes of this section, an unlawful employment practice occurs, with respect to discrimination in compensation in violation of this title, when a discriminatory compensation decision or other practice is adopted, when an individual becomes subject to a discriminatory compensation decision or other practice, or when an individual is affected by application of a discriminatory compensation decision or other practice, including each time wages, benefits, or other compensation is paid, resulting in whole or in part from such a decision or other practice.

When an individual is affected?

Sen. Kay Bailey Hutchison (R-TX) has submitted a substitute amendment to the bill. In her floor statement yesterday she clearly made the point:

[In] the bill before us there is a major change in common law and in tort law that has also been a part of our legal system and our case law since the beginning of law in our country and in other countries that have the types of laws we do; and that is that a tort accrues a right to the person who is offended or damaged or hurt by another action. It does not accrue to another person who is affected by or might be considered affected by this claim.

Now, there are exceptions to that. But in the main, it is, I think, essential, if we are going to have a statute of limitations that goes beyond the act itself--and in this case it would be 6 months, which is the law today--that it accrue to the person actually injured, the employee, and not some other person on behalf of the person who did not bring the case.

Under the Mikulski bill, the Ledbetter Act, a new right has been given to a person who may not be the person with the injury. So it could be a case where the person dies after working at a place of employment, a business. The person dies, and within 6 months of that person's last paycheck and subsequent death, some other person--an heir, a child, a mother, a father--could bring a case, which the person who has allegedly been discriminated against chose not to bring or did not bring. In such an absurd case, possible under the Ledbetter bill, you do not even have the person discriminated against to testify.

So much for the bill being a "narrow fix" of the Supreme Court ruling.

If you don't know about this consequence of the pending enactment, Michael Moore writes about it at the Pennsylvania Labor and Employment Blog.

The two labor/lawyer/grievance bills pass House - PointOfLaw Forum

Following up on Walter's posts of the day, we note the both bills passed on mostly partyline votes, as expected.

The House first passed H.R. 12, the Paycheck Fairness Act, by a vote of 256-163. Roll Call No. 8.

It then passed H.R. 11, the Lilly Ledbetter Fair Pay Act. The vote was 247-171. Roll Call No. 9. House Speaker Nancy Pelosi held the gavel for part of the debate, a symbolic statement of the importance Democratic leadership placed in the bills.

House Republican Leader John Boehner issued a statement in response to passage, "Flood of Special-Interest Bills Begins in Newly-Expanded Democratic Congress." Excerpt:

Today's effort by the Democratic Majority is not about workplace discrimination; it's the first step in an effort to begin rewarding the special-interest allies who helped give the Democratic Party control of Washington. These bills do not reflect the priorities of the American people; they reflect the narrow interests of the powerful trial lawyer industry that last year used its ill-gotten war chest to help the current majority tighten its grip on power.

House Majority Leader Steny Hoyer sees it differently, obviously, issuing two statements praising passage of the Paycheck Fairness Act (here) and the Ledbetter Fair Pay Act (here). I've got quite a few posts up on the bills over at Legal arguments aside, it's indisputable that these bills will raise the marginal costs of labor, discouraging the hiring of new employees -- a strange priority for lawmakers during a time of recession and layoffs.

Hans Bader on Ledbetter/PFA - PointOfLaw Forum

Legislate in haste, repent at leisure:

The trial lawyers will score another major victory [Friday], by obtaining House passage of two bills backed by Obama that will greatly expand the ability to sue employers. One, the Ledbetter Fair Pay Act , would effectively get rid of the statute of limitations in pay discrimination cases. The other, the Paycheck Fairness Act , would pressure some employers to pay people performing different jobs with very different working conditions the same pay , if the different jobs are predominantly held by different sexes, and the different jobs are deemed comparable based on specified statutory criteria.

Supporters of these bills have relied heavily on false claims about what the Supreme Court held in its Ledbetter decision, which did not adopt, as the bills' supporters claim, a rigid 180-day deadline for bringing pay discrimination cases . (There is a 3-year deadline under the Equal Pay Act , and the 180-day deadline under Title VII, which is simply one alternative avenue for bringing wage discrimination claims, is not rigid , but is subject to equitable "tolling "). False attacks on opponents of the bill were a staple of the 2008 presidential campaign, which featured TV ads from Obama, and mass mailings by state Democratic Parties, falsely claiming that McCain backed wage discrimination against women , simply because he did not support these two bills. Amazingly, the McCain campaign did almost nothing to counter those attacks.

We've often noted the press's lack of curiosity about the interaction between the Equal Pay Act and the issue the Court faced in Ledbetter. More today from a WSJ editorial.

"The Ledbetter Act: Sacrificing Justice for 'Fair' Pay" - PointOfLaw Forum

With the legislative train poised to leave the station on this employment-law expansion, Andrew Grossman of Heritage urges members of Congress to stop and think before undercutting the principles behind statutes of limitation, which every advanced legal system have found a crucial check on the tendency of disputes otherwise to proliferate without limit.

Environmental justice is to justice as ... - PointOfLaw Forum

The Senate Health, Education, Labor and Pensions Committee is the first committee out of the 111th Congressional gate to hold confirmation hearings on President-elect Obama's cabinet nominees. (More accurately: pre-confirmation hearings on anticipated nominees.) On Thursday, HELP hears from former Sen. Tom Daschle, the HHS Secretary-nominee, and on Friday, it's Rep. Hilda Solis (D-CA), the Obama pick to head the Department of Labor.

The business community has responded coolly, if at all, to the Solis nomination, given her near-perfect pro-labor voting record (100 percent in 2007, according to the AFL-CIO rankings; lifetime, 97 percent). We expect the hearing to be dominated by Senators' statements and the occasional question to the nominee about the Employee Free Choice and two pro-union, trial lawyer-supported bills to be voted on Thursday in the House, the Lilly Ledbetter Fair Pay Act, and the Paycheck Fairness Act. (See this POL post.)

It's hard to imagine such lines of inquiry producing much more than platitudes, boilerplate and niceties, at least from the nominee. We already know Solis supports the Employee Free Choice Act and has promoted the Paycheck Fairness Act, so is there anything new to learn?

Another, more productive area of questioning would explore Solis' advocacy of "environmental justice," that is, the argument that malign corporations pick out poor, disadvantaged and minority communities for their polluting facilities BECAUSE the communities house the poor, disadvantaged and minorities. At Solis' congressional website, the issue is framed as, "For decades, minority and underserved communities have been forced to live in close proximity to industrial zones, power plants, and toxic waste sites." Forced!

Solis touts her advocacy for this legally couched form of class warfare, taking credit for sponsoring as a California state Senator the "first environmental justice law" in the nation; she also received the "Profile in Courage" award from the John F. Kennedy Library Foundation for her efforts.

Many, many lawsuits against energy or infrastructure projects are represented as a matter of "environmental justice"; the term is the activist attorney's PR friend. (For examples, see this Riverside Press-Enterprise story on transmission lines and this Environmental News Service story, "Eco-Justice Groups Sue Over Chevron Refinery Expansion.")

Along similar lines, Solis embraces the "precautionary principle" in regulation of chemicals, that is, the demand that all chemicals be proved absolutely safe before being introduced into the marketplace.

The new Congress convenes, trial lawyer lobby smiles - PointOfLaw Forum

The 111th Congress convenes at noon today, and House Democratic leadership is starting the week with two bills that appeal to their core constituencies but send the business community into conniptions. The two pieces of legislation -- the Lilly Ledbetter Fair Pay Act and the Paycheck Fairness Act -- are priorities for organized labor, liberal women's advocacy groups, and the plaintiff's bar.

The Ledbetter bill (see POL's many earlier posts) is sold as a fix of the Supreme Court's decision in Ledbetter v. Goodyear Tire and Rubber. In its May 2007 ruling, (opinion here) the court said the employment law requires the filing of wage discrimination claims within a specified period of time. But rather than a limited fix, the bill would lift all statutes of limitations on such discrimination claims, inviting a flood of lawsuits on old, unprovable but potentially expensive claims that employers would find it hard to defend against.

It sounds like this year's bill is the same as the 110th Congress' legislation,  H.R. 2381, passed the House, 225-199, in July 2007.

The Paycheck Fairness Act is potentially worse, in that creates many new grounds for litigation in a supposed effort to fight gender discrimination. The bill, H.R. 1338 in the 110th Congress, passed in July 2008 by a vote of 247-178. It would:

  • Eliminate current caps on punitive and compensatory damages in claims made under the Equal Pay Act;
  • Expose employers to unlimited punitive and compensatory damage awards when unintentional pay disparities have occurred;
  • Eliminate key employer defenses for pay disparities;
  • Prohibit employers from disciplining or discharging employees for publicly disclosing sensitive wage information; and,
  • Mandate new federal government "guidelines" about the relative worth of different types of jobs.

In its original form, the legislation also included the old "comparable worth" guidelines.

We're now hearing that the bills will be debated under a closed rule, probably Thursday, indicating that quick passage rather than measured deliberation is the goal. Once both pass, they'll be combined into a single bill to send to the Senate, so perhaps this politicking is intended less as a reward to the trial lawyers and labor than a signal to the Senate to get moving.

In any case, a combined Ledbetter Paycheck Fairness and Sue Your Boss Act will certainly galvanize business opposition, even as many business groups are trying to work cooperatively with the new Obama Administration.

There are so many messages being sent, but clearly one of those messages goes to the plaintiff's bar. It's "Thank You."

Presidential debate invokes Lilly Ledbetter - PointOfLaw Forum

Sen. Obama criticized the Supreme Court opinion on statutes of limitation in employment discrimination suits; as Carter, Ted and other bloggers at this site have shown in numerous posts, such outrage is misplaced. Daniel Schwartz also comments and assembles several links, while Michael Fox at Jottings By an Employer's Lawyer points out that other fixes are available for the discontents in question.

The Senate Judiciary hearing on Ledbetter, fair pay - PointOfLaw Forum

The Senate Judiciary Committee today held a hearing, "Barriers to Justice: Examining Equal Pay for Equal Work," featuring testimony from Lilly Ledbetter, whose wage discrimination suit against Goodyear Rubber and Tire made it all the way to the Supreme Court in 2007. (Ledbetter v. Goodyear opinion here.) As we've noted previously, she has become an active supporter of Barack Obama's presidential campaign -- featured in anti-McCain ads -- and a symbol of grievance for labor and women's groups.

Eric Dreiband of Jones Day was originally scheduled to testify, but it appears that the business community was instead represented by Lawrence Lorber of Proskauer Rose. In his testimony, Lorber addresses H.R. 1338, the Paycheck Fairness Act, recent employment law cases before the Supreme Court, and the harm that class-action lawsuits cause in employment law. The final point: "The Class Action Is Neither An Appropriate Nor An Effective Mechanism For The Resolution of Statutor Employment Discrimination Claims." His conclusion:

[While] while the class action is intended to provide an effective and efficient mechanism to resolve legal claims held by numerous litigants, the mechanism has devolved into a moneymaking tool (albeit a very effective money-making tool) for plaintiff's attorneys. The settlement of large nation-wide class actions often results in attorney fee awards in the tens or hundreds of millions of dollars, while providing little relief to the class members. Used in this manner, the class action fails to provide justice for victims of discrimination. Instead, it makes a mockery of the equal employment opportunity laws. Congress should put a stop to this by enacting legislation to clarify the standards that govern employment discrimination class actions.

And the prepared statements...

Lilly Ledbetter
Lawrence Z. Lorber
Cyrus Mehri
The Honorable Diane Feinstein
The Honorable Patrick Leahy
The Honorable Russ Feingold

One last Ledbetter appearance in Congress - PointOfLaw Forum

It does not appear the Senate will have another vote on the "fair pay" legislation, i.e., H.R. 2831, the Ledbetter Fair Pay Act, which passed the House but failed to gain cloture last April in the Senate. However, Lilly Ledbetter does get one more moment in the congressional grievance spotlight this week, testifying at a Senate Judiciary Committee Hearing Tuesday, "Barriers to Justice: Examining Equal Pay for Equal Work."

Ever since the Supreme Court rejected her arguments in Ledbetter v. Goodyear Tire and Rubber, she's become a cause celebre, the embodiment of wage discrimination for the Democrats. Ms. Ledbetter had a prime speaking slot at the Democratic National Convention and campaigned last week with Michelle Obama in Richmond. In a trenchant post, "Lilly Ledbetter, Living a Lie," D.C. attorney and Powerline blogger Paul Mirengoff is having none of it, challenging the veracity of her arguments and reiterating the importance of statutes of limitation.

Prevented by the facts from arguing in a real court that she didn't have enough knowledge about her pay situation to bring a timely EEOC charge, Ledbetter (and those who seek political advantage through her) now raise this false claim in the court of public opinion. For example, Ledbetter claims that "the only way that I really knew [about the pay discrimination] was that someone left an anonymous note in my mailbox showing my pay and the pay for the three males who were doing the same job, just on different shifts." According to Ledbetter, "when I saw that note, it just floored me. I was so shocked at the amount of difference in our pay for doing the same exact job. And I went immediately to EEOC."

This claim, of course, cannot be reconciled with her sworn testimony that three years before allegedly receiving the "anonymous note," she told her supervisor that she definitely knew that she was making thousands less than her male counterparts for the same work.

Also testifying at Tuesday's hearing are employment law experts Eric S. Dreiband of Jones Day and Cyrus Mehri of Mehri & Skalet. Dreiband, the former EEOC's general counsel, moved from Akin Gump to Jones Day this July. And Mehri was featured in last week's "Ad Age" in a story headlined, "Top Lawyer Preps March on Mad Ave -- Man Who Beat Coke and NFL Starts to Study Diversity in Ad Agencies."

Mr. Mehri declined to discuss whether a lawsuit was in the works but said his firm was behind the preliminary results of a study obtained by Ad Age. Any way you look at it, the fact that a top civil-rights attorney has commissioned a survey of diversity in ad agencies does not bode well for the agencies whose ranks are still overwhelmingly white.

Can't wait for the congressional hearings.

Legal issues in Congress in the month ahead - PointOfLaw Forum

Politico's The Crypt blog publishes the e-mail from the Senate Democratic Caucus on the issues leadership intends to address before adjourning (one target date is September 26). Energy figures prominently, and the entire list is shaped by electoral politics, of course.

Those issues with the most direct effect on business-related litigation (save for judge confirmations), priorities as identified by the Senate Majority Leader:  

  • Americans with Disabilities Restoration Act: Business groups like my employer, the National Association of Manufacturers, have reached a modus vivendi with disability advocates and accept the legal burdens represented by the legislation. The Heritage Foundation is much more critical, although it finds the Senate version, S. 3406, far preferable for business than the version that passed the House, H.R. 3195.
  • Equal pay legislation, i.e., the Ledbetter legislation, which would eliminate statutes of limitation in employment discrimination suits and wreak other legal mischief. The Senate failed to envoke cloture on H.R. 2831 in April, and another run at the bill would remind voters of Sen. Obama's support and Sen. McCain's opposition. For previous posts on the subject, go here.
  • Federal media shield, i.e., the Free Flow of Information Act. Senator Reid pushed S. 2035 to a cloture vote right before the August recess but Republicans blocked consideration to increase pressure for a vote on energy legislation. The major media continue to lobby for the federal media shield (c.g. this L.A. Times editorial and this Atlanta Journal-Constitution op-ed from the head of the Society of Professional Journalists, "Shield law needed, not for press, but for democracy"), so Senate action can be seen as an effort to shore up the base.

And that appears to be it, although it wouldn't be surprising to see an anti-binding-arbitration measure slip through someplace.

UPDATE (3 p.m.): Now that we look at it again, Politico's speculation notwithstanding, it's possible that Sen. Reid's e-mail referred to the Paycheck Fairness Act, H.R. 1338, which passed the House on August 1. Among other things, it would lift the cap on punitive damages for suits filed under the Equal Pay Act. Daniel Schwartz recently wrote about the legislation at

Pictures of Lilly - PointOfLaw Forum

Lilly Ledbetter's remarks to the Democratic National Convention proved short and of no great impact in Denver yesterday, the standard marking of a box on a convention check list. (Her remarks are here.)

We thought her appearance in a prime evening spot might signal a final push by the congressional majorities to pass legislation reacting to Ledbetter v. Goodyear, a bill that would eliminate statutes of limitations in employment discrimination cases. And certainly the female members of Congress who had a platform Tuesday used her case in attacking McCain. (CQ Politics story.)

But Ledbetter's speech itself was unremarkable, overshadowed by the day's big story, the Hillary hubbub. Ledbetter:

We can't afford more of the same votes that deny women their equal rights. Barack Obama is on our side. He is fighting to fix this terrible ruling, and as president, he has promised to appoint justices who will enforce laws that protect everyday people like me. But this isn't a Democratic or a Republican issue. It's a fairness issue. And fortunately, there are some Republicans--and a lot of Democrats--who are on our side.

Sen. Obama did make an effort to attend and vote for cloture on H.R. 2831 in April, a good political move. (As did Sen. Clinton.)

The Birmingham News had a short story. For previous Point of Law posts on Ledbetter, go here.

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