Young v. United Parcel Service

Supreme Court of the United States · 2015 · Family Law

Family LawPregnancy Discrimination ActTitle VIIEmployment Discriminationpregnancy discriminationTitle VIIPDAdisparate treatment

Facts

Peggy Young worked as a part-time UPS driver, and during her pregnancy her doctor restricted her from lifting more than 20 pounds early in pregnancy and 10 pounds thereafter. UPS required drivers like Young to be able to lift up to 70 pounds and told her she could not work while under that restriction, leaving her without pay for much of her pregnancy and causing her to lose medical coverage. Young argued that UPS accommodated other employees who were similar in their ability or inability to work, including some employees injured on the job, some covered by the ADA, and some who lost Department of Transportation certifications. She also introduced evidence that UPS had accommodated several individuals with work restrictions similar to hers.

Issue

How does the Pregnancy Discrimination Act's command that pregnant women be treated the same as other persons similar in their ability or inability to work apply when an employer accommodates many, but not all, nonpregnant workers with work limitations? More specifically, can a pregnant employee use the McDonnell Douglas framework to show disparate treatment based on the employer's refusal to accommodate a pregnancy-related work restriction?

Rule

A pregnant worker asserting disparate treatment through indirect evidence may proceed under the McDonnell Douglas framework by showing that she is in the protected class, sought an accommodation, was denied the accommodation, and that the employer accommodated others similar in their ability or inability to work. The employer may then offer a legitimate, nondiscriminatory reason, but that reason normally cannot be merely that accommodating pregnant workers would be more expensive or less convenient. The plaintiff may show pretext by presenting sufficient evidence that the employer's policies impose a significant burden on pregnant workers and that the employer's stated reasons are not sufficiently strong to justify that burden, thereby supporting an inference of intentional discrimination.

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

Sonia Patel works as a warehouse clerk for Lakefront Office Supply in Cleveland, Ohio. During pregnancy, her doctor limits her to lifting no more than 15 pounds, and the company denies her request for temporary light duty. Sonia shows that the company gives temporary desk assignments to employees with lifting restrictions caused by shoulder injuries, vertigo, and temporary vision problems.

If Sonia proceeds with a disparate-treatment claim based on indirect evidence, which is the strongest argument that she has established a prima facie case?

Explanation. Under the majority opinion, a pregnant worker using indirect evidence may make out a prima facie case by showing she belongs to the protected class, sought accommodation, was denied, and the employer accommodated others similar in their ability or inability to work. The Court rejected both automatic entitlement and most-favored-worker theories. (Derived from Young v. United Parcel Service (n.d.).)