Young v. United Parcel Service, Inc.

2015-03-25

Headline: Pregnancy accommodation rules expanded; Court vacates lower-court win for employer and requires closer scrutiny when pregnant workers get fewer accommodations than similar nonpregnant coworkers.

Holding: The Court held that the Pregnancy Discrimination Act requires courts to assess whether an employer treats pregnant workers worse than nonpregnant workers with similar work limitations, using the McDonnell Douglas framework and allowing remand for factual inquiry.

Real World Impact:

Allows pregnant employees to challenge employer accommodation policies at trial.
Requires courts to compare pregnant workers with similarly limited nonpregnant coworkers.
May force employers to justify why they deny pregnancy-related accommodations.

Topics: pregnancy accommodations, workplace discrimination, employee benefits, employer policies

Summary

Background

A part-time UPS driver who became pregnant had a doctor’s lifting restriction and could not meet UPS’s heavy-lifting requirements, so she stayed home without pay and sued. She said UPS gave special accommodations to some nonpregnant drivers (for on-the-job injuries, lost DOT certification, or ADA-covered disabilities) but refused to accommodate her pregnancy-related restriction. The District Court and the Fourth Circuit sided with UPS and granted summary judgment for the employer.

Reasoning

The Court interpreted the Pregnancy Discrimination Act’s second sentence to require judges to compare how employers treat pregnant workers with how they treat nonpregnant workers who are similar in their ability or inability to work. When a plaintiff uses indirect evidence, the familiar burden-shifting framework applies: the worker makes an initial showing, the employer offers legitimate nondiscriminatory reasons, and the worker may then show those reasons are pretextual. The Court said employers cannot hide behind a neutral-sounding policy without courts weighing whether that policy, in practice, imposes a significant burden on pregnant employees and whether the employer’s justifications are strong enough to avoid an inference of intentional discrimination.

Real world impact

The Court vacated the Fourth Circuit’s judgment and sent the case back for further factfinding. This decision allows pregnant workers to try to show at trial that combined employer policies create a significant burden and that employer explanations are pretextual, rather than ending such claims at summary judgment. It does not decide the final merits and leaves factual questions for the lower court.

Dissents or concurrances

Justice Alito concurred in the judgment but emphasized comparisons should focus on similar jobs and neutral business reasons; Justice Scalia (joined by others) dissented, warning the majority blurred disparate-impact and disparate-treatment rules and invented a new balancing test.