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equal pay for equal work + the paycheck-restart clock

Equal Pay Act and Lilly Ledbetter

1963

EPA Year

FLSA amendment, sex-based pay

4

Defenses

Seniority, merit, production, "any other"

2009

Lilly Ledbetter

Each paycheck restarts 180-day clock

same snack · same price · no exceptions

The Equal-Pay Vending Machine

Picture a vending machine where the same snack appears in every slot. Equal Pay Act says the price is the same regardless of who is buying. Four receipts on the side allow legitimate price differences — sex isn't one of them.

Equal Pay Co.established 1963SAMEWORKA1employee 1$1.00SAMEWORKA2employee 2$1.00SAMEWORKA3employee 3$1.20← violates EPASAMEWORKA4employee 4$1.00push button · receive equal payreceipts · 4 valid reasonsdefense #1Senioritydefense #2Meritdefense #3Productiondefense #4Any factor not sexkeep these · burden of proof on employer180-dayclockLilly Ledbetterrestarts each paycheck →

how to read this

  • › Every snack in slot A is the SAME WORK. EPA says price tags must match — unless one of the four receipts justifies the difference.
  • › Slot A3's wrong price is a violation. The other three slots are fine.
  • › The Lilly Ledbetter clock on the side restarts every time the machine charges you. The 180-day window starts fresh with every paycheck.

Damages on Violation

back pay

2 yrs

3 yrs if willful

+ liquidated

double the back pay

+ legal fees

paid

attorney + costs

Exam Traps

EPA covers SEX only

Race-based pay discrimination falls under Title VII, not the Equal Pay Act. The exam tests scope.

"Substantially equal" — not identical

Equal skill, effort, responsibility, similar working conditions. Different titles can still be substantially equal work.

Lilly Ledbetter resets, not extends

It does not lengthen the 180-day window forever. Each new discriminatory paycheck restarts the clock anew.

"Any factor other than sex" requires proof

Employer must show the factor is genuinely unrelated to sex. Vague gestures at "experience" or "negotiation" can fail under scrutiny.

EPA = sex only

Race, age, disability pay discrimination uses other statutes. Do not stretch EPA to cover them.

Each paycheck = new clock

Lilly Ledbetter (2009) reset the rule from Ledbetter v. Goodyear. Older claims are not foreclosed by silence.

1
Same snack, different prices?

A machine where the same snack costs different amounts depending on who pushes the button. EPA says no. Same snack, same price.

2
The receipt is the defense

If the receipt shows the price differs because of seniority, merit, production, or any non-sex factor — the employer is OK.

3
Lilly Ledbetter restarts the clock

Each time the machine charges you the wrong price, the clock starts over. Not just the first time.

4
Damages double on bad faith

EPA awards back pay (2-3 years) plus liquidated damages doubling that amount.

Equal Pay = equal price. Four receipts allowed. Lilly Ledbetter restarts the clock with every transaction.
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Reviewed by Sarah L., PrepSolution Content Editor, HR
Sources verified against HRCI 2026 standards
Updated May 2026