Supreme Court Rules on Pregnancy Discrimination Case

 
Wednesday, April 1, 2015
 

In Young v. United Parcel Service, Docket No. 12-1226 (March 25, 2015), the Supreme Court determined whether the Pregnancy Discrimination Act (PDA) prohibits an employer from denying a light-duty accommodation to pregnant workers that is available to other employees.

The Pregnancy Discrimination Act provides that pregnant employees shall be treated the same for all employment-related purposes as other employees who are "similar in their ability or inability to work." In this case, the employer offered light-duty accommodations to employees who were injured on the job and to disabled workers but denied the same accommodation to pregnant employees.  Petitioner Young was a part-time driver for United Parcel Service (UPS). When she became pregnant, her doctor advised her that she should not lift more than 20 pounds. UPS, however, required drivers like Young to be able to lift up to 70 pounds. UPS told Young that she could not work while under a lifting restriction. Young subsequently filed the federal lawsuit, claiming that UPS acted unlawfully in refusing to accommodate her pregnancy-related lifting restriction.  The Petitioner argued that UPS policies that accommodated workers who were injured on the job, had disabilities covered by the Americans with Disabilities Act of 1990 (ADA), or had lost Department of Transportation (DOT) certifications. Pursuant to these policies, Young contended, UPS had accommodated several individuals whose disabilities created work restrictions similar to hers. She argued that these policies showed that UPS discriminated against its pregnant employees because it had a light-duty-for-injury policy for numerous “other persons,” but not for pregnant workers. UPS responded that, since Young did not fall within the on-the-job injury, ADA, or DOT categories, it had not discriminated against Young on the basis of pregnancy, but had treated her just as it treated all “other” relevant “persons.”

The Supreme Court held that Young created a genuine dispute as to whether UPS provided more favorable treatment to at least some employees whose situation cannot reasonably be distinguished from hers. The Supreme Court left to the Fourth Circuit to determine on remand whether Young also created a genuine issue of material fact as to whether UPS’ reasons for having treated Young less favorably than these other nonpregnant employees were pretextual.

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