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California Federal Savings & Loan Ass'n v. Guerra

Supreme Court of the United States · 1987 · Constitutional Law

Constitutional LawFederal PreemptionEmployment DiscriminationPregnancy Discrimination ActTitle VIISupremacy ClausepreemptionTitle VII

Facts

California's Fair Employment and Housing Act required covered employers to provide female employees up to four months of unpaid leave for actual pregnancy disability, and the state commission interpreted the statute to require reinstatement to the same job unless unavailable due to business necessity, with good-faith efforts to place the employee in a substantially similar job. Cal Fed, a covered employer under both Title VII and the California statute, had a neutral leave policy but reserved the right to terminate an employee returning from leave if no similar position was available. Employee Lillian Garland took pregnancy disability leave, sought to return, and was told her job had been filled and no similar positions were available. State enforcement authorities charged Cal Fed with violating the California statute, prompting this preemption suit.

Issue

Does Title VII, as amended by the Pregnancy Discrimination Act of 1978, preempt a California law requiring employers to provide unpaid leave and reinstatement rights to employees disabled by pregnancy? More specifically, does the PDA forbid states from requiring pregnancy-specific leave and reinstatement benefits beyond those provided to other disabled employees?

Rule

Under Title VII's anti-preemption provisions, state employment laws are preempted only if they actually conflict with federal law—either by requiring or permitting conduct that would be an unlawful employment practice under Title VII, or by being inconsistent with the purposes of the Act. The Pregnancy Discrimination Act was intended to establish a floor beneath which pregnancy disability benefits may not fall, not a ceiling above which states may not go, so long as the state law is narrowly directed at actual pregnancy disability and does not rest on stereotypes inconsistent with equal employment opportunity.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Oregon enacts a statute requiring covered employers to provide up to 10 weeks of unpaid leave, plus reinstatement to the same or a substantially similar position, for employees who are actually physically disabled by pregnancy. Rivergate Lending Group, a fictional lender in Portland, gives all temporarily disabled workers unpaid leave but guarantees reinstatement only to employees covered by the Oregon statute. A male employee argues the state law is preempted by federal law because it gives pregnancy-specific protection.

How should a court rule on the employer's preemption challenge?

Explanation. Under the majority opinion, Congress expressly disclaimed field preemption in this area, and Title VII preempts only state laws that actually conflict with federal law. The PDA sets a floor, not a ceiling, for pregnancy-disability benefits. A state law limited to actual physical disability from pregnancy, with leave and reinstatement rights, is not preempted so long as it does not require conduct unlawful under Title VII or frustrate Title VII's purposes.