California Federal Savings & Loan Ass'n v. Guerra
1987 U.S. LEXIS 284, 479 U.S. 272, 93 L. Ed. 2d 613 (1987)
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Rule of Law:
The Pregnancy Discrimination Act (PDA) amendment to Title VII establishes a minimum standard for pregnancy disability benefits, not a maximum. A state law is not preempted by the PDA if it provides greater protection to pregnant employees, so long as it does not compel employers to violate Title VII or frustrate the statute's purpose of achieving equal employment opportunity.
Facts:
- California's Fair Employment and Housing Act (FEHA) requires employers to provide female employees up to four months of unpaid disability leave for pregnancy and a qualified right to reinstatement upon their return.
- California Federal Savings & Loan Association (Cal Fed) maintained a facially neutral leave policy that allowed unpaid leave for various disabilities but did not guarantee reinstatement, expressly reserving the right to terminate an employee if a similar position was not available.
- Lillian Garland, a receptionist at Cal Fed, took a pregnancy disability leave in January 1982.
- When Garland was medically cleared to return to work in April 1982, Cal Fed informed her that her position had been filled and no similar jobs were available.
- Garland filed a complaint with the California Department of Fair Employment and Housing.
- The Department issued an administrative accusation against Cal Fed, charging it with violating the state's FEHA by failing to reinstate Garland.
Procedural Posture:
- California Federal Savings & Loan Association sued the California Department of Fair Employment and Housing in the U.S. District Court for the Central District of California.
- The lawsuit sought a declaratory judgment that the California pregnancy leave statute was preempted by Title VII and an injunction against its enforcement.
- The District Court granted summary judgment for Cal Fed, holding the California law was preempted by federal law.
- The California Department of Fair Employment and Housing, as the defendant, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit reversed the District Court, holding that the state law was not preempted by Title VII.
- Cal Fed, as the petitioner, successfully sought a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does Title VII of the Civil Rights Act of 1964, as amended by the Pregnancy Discrimination Act, preempt a state statute that requires employers to provide leave and reinstatement to employees disabled by pregnancy?
Opinions:
Majority - Justice Marshall
No. Title VII, as amended by the PDA, does not preempt the California statute. The federal law was intended to be 'a floor beneath which pregnancy disability benefits may not drop — not a ceiling above which they may not rise.' The PDA's purpose was to prohibit discrimination against pregnant employees, not to prohibit states from enacting laws that provide them with favorable treatment. The California statute is consistent with Title VII's goal of achieving equality of employment opportunities, as it ensures women are not forced to choose between having a family and keeping their job. Furthermore, compliance with both laws is not a physical impossibility; employers can comply with the California law by providing the required leave and can comply with Title VII by extending similar benefits to other disabled employees.
Dissenting - Justice White
Yes. The California statute is preempted by the PDA. The plain language of the PDA mandates that pregnant employees 'shall be treated the same for all employment-related purposes' as other persons with a similar ability or inability to work. This language leaves no room for preferential treatment. The California law, by requiring a leave policy for pregnancy even if an employer has none for other disabilities, is in 'square conflict' with the PDA's command for equal, not favorable, treatment. The majority's 'floor, not a ceiling' interpretation is contrary to clear legislative history indicating Congress's intent was to treat pregnancy functionally the same as other disabilities, not to place it in a special class.
Concurring - Justice Stevens
No. The PDA, as part of Title VII, does not mandate absolute neutrality and allows for some preferential treatment consistent with the statute's goals. Citing Steelworkers v. Weber, which held that Title VII does not prohibit all preferential treatment for disadvantaged classes, this opinion argues the PDA should be interpreted similarly. Since Title VII permits some special preferences to achieve its goal of equal opportunity, the PDA allows for preferential treatment of pregnancy so long as it serves that same goal. The California statute, by removing a barrier to equal employment for women, meets this test.
Concurrence - Justice Scalia
No. The judgment should be affirmed on narrower grounds. The court need not decide whether the PDA allows preferential treatment because Title VII's anti-preemption provision, § 708, is dispositive. Section 708 only preempts state laws that 'require or permit the doing of any act which would be an unlawful employment practice.' The California statute does not require an employer to treat other disabled employees unequally; it is silent on that matter. Therefore, it does not compel any unlawful act under Title VII, and it cannot be preempted, making any broader interpretation of the PDA an unnecessary advisory opinion.
Analysis:
This decision establishes that the federal Pregnancy Discrimination Act provides a baseline of protection that states are free to exceed. It endorses a substantive, rather than purely formal, view of equality, allowing states to enact laws that specifically account for the unique physical conditions of pregnancy to ensure women have equal opportunities in the workplace. The ruling affirmed the power of states to create more generous and family-friendly employment policies, solidifying the 'floor, not a ceiling' interpretation of the PDA and rejecting the argument that equality requires identical treatment for all disabilities.
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