25 March 2015

Law in Plain English: Young v. United Parcel Service

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogYoung v. United Parcel Service

Argument: Dec 3 2014 (Aud.)

Background: Peggy Sue Young was a part-time "air driver" for UPS, responsible for picking up and delivering packages that arrived by air carrier the previous night. During a leave of absence, Young became pregnant and left a doctor's note with her supervisor that she should not lift more than twenty pounds during the first twenty weeks of her pregnancy and not more than ten pounds thereafter. UPS's occupational health manager, Carolyn Martin, informed Young that UPS policy prevented Young from working while she was under the 20 pound restriction. Martin also determined that Young was ineligible for light duty assignment because light duty was only permitted for those with on-the-job injuries (as opposed to off-the-job injuries), those accommodated under the Americans with Disabilities Act (ADA) (federal courts have largely held that pregnancy is not a "disability" under the ADA), and those who had lost their Department of Transportation (DOT) certification, but not for pregnancy. Young filed a charge with the Equal Opportunity Employment Commission (EEOC), which issued Young a right to sue letter. Young then filed suit, alleging, among other things, that UPS's policy violated the Pregnancy Discrimination Act (PDA). The district court concluded that Young had not shown direct evidence of discrimination. Likewise, she failed to establish a prima facie case of sex discrimination. The Fourth Circuit affirmed. The panel reasoned that the text of the PDA was placed in the definitions section of Title VII; and as a result, it does not create a "distinct and independent cause of action" that would otherwise cause pregnancy to be treated more favorably than any other basis, including non-pregnancy-related sex discrimination covered by Title VII. A policy that treats pregnant and non-pregnant workers alike complied with the PDA. Even though UPS's policy might have been "insufficiently charitable," a lack of charity itself did not rise to discriminatory animus directed at pregnant employees.

Issue: The question before the Court are whether, and in what circumstances, the Pregnancy Discrimination Act, 42 U.S.C. § 2000e(k), requires an employer that provides work accommodations to non-pregnant employees with work limitations to provide work accommodations to pregnant employees who are "similar in their ability or inability to work."

Holding: In a 6-3 decision, the Supreme Court ruled that an individual pregnant worker who seeks to show disparate treatment through indirect evidence may do so through application of the McDonnell Douglas framework by showing that she belongs to the protected class, that she sought accommodation, that the employer did not accommodate her, and that the employer did accommodate others “similar in their ability or inability to work.” The employer may then seek to justify its refusal to accommodate the plaintiff by relying on “legitimate, nondiscriminatory” reasons for denying accommodation.
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