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Wimberly v. Labor and Industrial Relations Comm'n of Mo.

Supreme Court of the United States
1987 U.S. LEXIS 417, 93 L. Ed. 2d 909, 479 U.S. 511 (1987)
ELI5:

Rule of Law:

The Federal Unemployment Tax Act, 26 U.S.C. § 3304(a)(12), prohibits states from singling out pregnancy for unfavorable treatment in unemployment compensation laws but does not mandate preferential treatment for pregnant claimants.


Facts:

  • Linda Wimberly was an employee of J. C. Penney Company for approximately three years.
  • In August 1980, Wimberly requested and was granted a leave of absence due to her pregnancy.
  • The company's policy was a 'leave without guarantee of reinstatement,' meaning she would only be rehired if a position was available upon her return.
  • Wimberly's child was born on November 5, 1980.
  • On December 1, 1980, Wimberly notified J. C. Penney that she wished to return to work, but was informed that no positions were open.
  • Wimberly filed for unemployment benefits under Missouri law.
  • Missouri law disqualifies any claimant who 'has left his work voluntarily without good cause attributable to his work or to his employer.'

Procedural Posture:

  • Wimberly's claim for unemployment benefits was denied by the Missouri Division of Employment Security.
  • The Division's appeals tribunal affirmed the denial after a hearing.
  • The Labor and Industrial Relations Commission denied Wimberly's petition for review.
  • Wimberly sought review in the Circuit Court of Jackson County, Missouri, which reversed the Commission's decision, finding the state law inconsistent with federal law.
  • The Missouri Court of Appeals affirmed the Circuit Court's judgment.
  • The Labor and Industrial Relations Commission appealed to the Missouri Supreme Court, which reversed the Court of Appeals' decision.
  • Wimberly (the petitioner) was granted a writ of certiorari by the U.S. Supreme Court.

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Issue:

Does the Federal Unemployment Tax Act, 26 U.S.C. § 3304(a)(12), prohibit a state from disqualifying an unemployment claimant who left her job due to pregnancy, when the state's law disqualifies all claimants who leave their jobs for reasons not causally connected to their work or employer?


Opinions:

Majority - Justice O'Connor

No. The Federal Unemployment Tax Act does not prohibit a state from disqualifying a claimant who left work due to pregnancy if the disqualification is based on a neutral, generally applicable rule. The statute, which forbids denying compensation 'solely on the basis of pregnancy,' is an anti-discrimination provision, not a preferential treatment mandate. Missouri’s law disqualifies all persons who leave work for reasons not connected to the work or the employer; it does not single out pregnancy. Because the state’s decision to deny benefits could be made without knowing the claimant was pregnant—only that she left for a reason not attributable to her employer—pregnancy is not the 'sole basis' for the denial. The court's reasoning is supported by the plain language of the statute, legislative history showing Congress intended to target only state laws with special, discriminatory provisions against pregnancy, and the consistent interpretation of the Department of Labor, the agency charged with enforcing the Act.



Analysis:

This decision clarifies that the federal prohibition against pregnancy-based unemployment denials is a 'floor' of non-discrimination, not a 'ceiling' of mandated benefits. It affirms significant state discretion in setting neutral qualification standards for unemployment, even if those standards have a disparate impact on a protected group like pregnant women. The ruling distinguishes between facially discriminatory laws, which are prohibited, and neutral rules of general applicability, which are permissible under this statute. This allows states to maintain stricter 'good cause' requirements for all claimants without creating a federal exception for pregnancy.

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