United States Supreme Court
Young v. United Parcel Service, Inc., 12-1226
When plaintiff became pregnant, she was told by her employer, defendant United Parcel Service, that she could not work while under a pregnancy lifting restriction due to the nature of her job as a part-time driver handling packages. Plaintiff alleges that defendant acted unlawfully in refusing to accommodate her pregnancy-related lifting restriction. Plaintiff further alleges that defendant had, pursuant to its internal policies, accommodated several individuals whose disabilities created work restrictions similar to hers. The district court granted summary judgment in favor of defendant, and the Fourth Circuit affirmed. The judgment is vacated and the case is remanded, where: 1) the Pregnancy Discrimination Act requires that employers provide similar accommodations as they do to any other persons who are similar in their ability or inability to work; 2) a pregnant worker demonstrating disparate treatment may make out a prima facie case under the McDonnell Douglas framework by showing that she belongs to the protected class, that she sought accommodation, that the employer did not accommodate her, and that the employer did accommodate others similarly situated in their ability to work; 3) there is a genuine dispute as to whether defendant provided more favorable treatment to at least some employees whose situation cannot reasonably be distinguished from plaintiff's; 4) plaintiff introduced evidence that defendant had three separate accommodation policies, and taken together, these policies significantly burdened pregnant women; and 5) the Fourth Circuit did not consider the combined effects of these policies, nor did it consider the strength of defendant's justifications for each when combined.
- Decided 03/25/2015
- Published 03/25/2015
- United States Supreme Court