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Young v. United Parcel Service, Inc.

Supreme Court of the United States
135 S.Ct. 1338, 191 L. Ed. 2d 279, 2015 U.S. LEXIS 2121 (2015)
ELI5:

Rule of Law:

Under the Pregnancy Discrimination Act (PDA), a plaintiff can establish a prima facie case of disparate treatment by showing that her employer denied her an accommodation for a pregnancy-related work limitation while accommodating other employees similar in their ability or inability to work. An employer's justification for such a policy can be challenged as pretextual if it imposes a significant burden on pregnant workers and the employer's legitimate, nondiscriminatory reasons are not sufficiently strong to justify that burden.


Facts:

  • Peggy Young worked as a part-time driver for United Parcel Service (UPS).
  • The job required drivers to be able to lift packages weighing up to 70 pounds.
  • In 2006, Young became pregnant, and her doctor advised her not to lift more than 20 pounds.
  • UPS informed Young that she could not work while under the lifting restriction, forcing her to take an unpaid leave of absence during which she lost her medical coverage.
  • UPS had policies to accommodate other employees who were temporarily unable to perform their regular duties.
  • These policies provided alternative work assignments for drivers who (1) were injured on the job, (2) had a disability covered by the Americans with Disabilities Act (ADA), or (3) lost their Department of Transportation (DOT) certification.
  • Young's pregnancy-related restriction did not place her in any of these three categories eligible for accommodation.

Procedural Posture:

  • Peggy Young sued United Parcel Service (UPS) in the U.S. District Court for the District of Maryland for pregnancy discrimination.
  • The District Court granted summary judgment in favor of UPS, finding Young could not establish a prima facie case.
  • Young, as the appellant, appealed the decision to the U.S. Court of Appeals for the Fourth Circuit.
  • The Fourth Circuit affirmed the trial court's grant of summary judgment for UPS, the appellee.
  • The U.S. Supreme Court granted Young's petition for a writ of certiorari to review the Fourth Circuit's decision.

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Issue:

Does an employer's policy that denies accommodations to pregnant workers while granting them to a large percentage of non-pregnant workers with similar inabilities to work violate the Pregnancy Discrimination Act?


Opinions:

Majority - Justice Breyer

Yes. An employer's policy may violate the Pregnancy Discrimination Act (PDA) if it accommodates a large percentage of non-pregnant workers while failing to accommodate pregnant workers with similar work limitations. The PDA's second clause requires more than a simple comparison within facially neutral policy categories. A plaintiff can establish a prima facie disparate-treatment claim under the McDonnell Douglas framework by showing she belongs to the protected class, sought an accommodation, was denied, and that the employer accommodated others 'similar in their ability or inability to work.' If the employer offers a legitimate, nondiscriminatory reason for its policy, the plaintiff can show pretext by providing evidence that the employer’s policies impose a 'significant burden' on pregnant workers and that the employer’s reasons are not 'sufficiently strong to justify the burden,' giving rise to an inference of intentional discrimination.


Concurring - Justice Alito

Yes. The Pregnancy Discrimination Act's second clause adds a requirement of equal treatment irrespective of intent, separate from the first clause's ban on intentional discrimination. UPS failed to provide a plausible, neutral business justification for treating pregnant drivers less favorably than drivers who lost their DOT certification for reasons that similarly limited their physical abilities. The court of appeals' reasoning for distinguishing between these groups was inadequate, as a lost DOT certification does not explain why an accommodation was provided, only why the driver could not perform their normal job. Therefore, a genuine issue of fact exists as to whether UPS violated this equal treatment mandate.


Dissenting - Justice Scalia

No. An employer's policy does not violate the Pregnancy Discrimination Act so long as it is evenhanded and does not discriminate because of pregnancy. The PDA's 'same-treatment' clause simply requires that pregnant women be entitled to accommodations on the same terms as other workers with disabling conditions, not that they receive the same accommodations regardless of neutral policy differences. The majority invents a new 'significant burden' and 'sufficiently strong justification' test that is not found in the statute's text and improperly conflates the distinct legal theories of disparate treatment and disparate impact. UPS's policy treated Young the same as any other worker who did not fit into its specific accommodation categories.


Dissenting - Justice Kennedy

No. While the difficulties pregnant women face in the workplace are a matter of serious societal concern, the Court's interpretation of the PDA is incorrect. Joining Justice Scalia's dissent, the majority's new test improperly risks a 'conflation of disparate impact with disparate treatment' and injects unnecessary confusion into the established McDonnell Douglas burden-shifting framework. Young did not show that UPS's policy was driven by animus against pregnant women, as many other non-pregnant workers with health restrictions were also denied accommodation.



Analysis:

This decision significantly alters the landscape for pregnancy discrimination claims by establishing a new, more plaintiff-friendly framework for proving disparate treatment. It moves beyond a rigid 'similarly situated' comparator analysis, allowing plaintiffs to use evidence of an employer's overall accommodation policies to show pretext. By focusing on whether policies impose a 'significant burden' on pregnant workers without a 'sufficiently strong justification,' the Court makes it harder for employers to defend facially neutral accommodation policies that, in practice, exclude pregnant employees while accommodating a large number of other non-pregnant employees.

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