Effects of past intentional discrimination do not restart the clock for filing a charge of discrimination with the EEOC

In order to bring a claim under Title VII of the Civil Rights Act of 1964, an employee must file a charge with the EEOC within either 180 or 300 days (depending on the State) after the alleged unlawful employment action that forms the basis of the claim. In many employment decisions, the date of that adverse action is easily ascertained. In claims of pay discrimination, however, courts have been divided over the issue of how far back a plaintiff can look for an intentionally discriminatory decision, especially where that individual's pay was subject to periodic reassessment, such as on an annual basis.