Turner v. Department of Employment Security of Utah

Background

Mary Ann Turner, a woman who was involuntarily separated from her job for reasons unrelated to pregnancy, applied for Utah unemployment benefits. She received payments until twelve weeks before her expected delivery, when the state stopped benefits under a Utah law that disqualified women from twelve weeks before birth until six weeks after. The Utah Supreme Court upheld that statutory 18-week rule, and Mrs. Turner appealed to the United States Supreme Court claiming the rule violated her Fourteenth Amendment protections.

Reasoning

The Court considered whether a blanket rule that presumes all pregnant women are unable to work for an 18-week period is constitutional. Relying on earlier decisions, the Court explained that such a conclusive presumption is improper because the ability to work during pregnancy varies greatly by individual. The opinion noted Mrs. Turner herself worked intermittently during the period the law treated her as universally incapacitated. The Court held the statute’s automatic 18-week disqualification violated the Constitution and required more individualized determinations about a woman’s ability to work.

Real world impact

The ruling means state unemployment systems cannot automatically deny benefits to all women during a fixed period around childbirth. Agencies must consider each woman’s actual ability to work rather than relying on a blanket presumption. The case was vacated and sent back to the Utah Supreme Court for further proceedings consistent with this opinion, so additional steps in the state courts will follow.

Dissents or concurrances

Two Justices preferred full briefing and argument instead of a summary decision. One Justice formally dissented from the per curiam outcome.