Summary
The Supreme Court interpreted the Pregnancy Discrimination Act's requirement that pregnant workers be treated the same as other persons similar in their ability or inability to work. The Court held that a pregnant employee may establish a disparate-treatment claim under the McDonnell Douglas framework by showing that the employer accommodated other similarly limited workers, after which the employer may provide legitimate, nondiscriminatory reasons subject to pretext analysis. The Court vacated and remanded the Fourth Circuit's judgment affirming summary judgment for United Parcel Service.
Questions Presented
- Whether a pregnant employee asserting disparate treatment under the Pregnancy Discrimination Act may proceed under the McDonnell Douglas burden-shifting framework.
- What showing establishes a prima facie case when an employer accommodates some nonpregnant employees with work limitations but does not accommodate a pregnant employee with a similar ability or inability to work.
- Whether the Fourth Circuit properly affirmed summary judgment for UPS.
Holdings
- A pregnant employee alleging disparate treatment through indirect evidence may proceed under the McDonnell Douglas burden-shifting framework.
- A plaintiff may establish a prima facie case by showing that she belongs to the protected class, sought an accommodation, the employer denied the accommodation, and the employer accommodated others similar in their ability or inability to work.
- An employer may justify denial of an accommodation with a legitimate, nondiscriminatory, nonpretextual reason, but a justification ordinarily cannot consist simply of claiming that accommodating pregnant women would be more expensive or less convenient. A plaintiff may create a jury issue by showing that the employer's policies impose a significant burden on pregnant workers and that the stated reasons are not sufficiently strong to justify that burden.
- Summary judgment for UPS was improper because Young presented a genuine dispute as to whether UPS gave more favorable treatment to some employees whose situations could not reasonably be distinguished from hers, and the lower court had not properly evaluated the combined effect of UPS's accommodation policies or the strength of its justifications.
Factual background
Peggy Young, a part-time UPS driver, became pregnant in 2006 and was medically restricted from lifting more than 20 pounds initially and 10 pounds later in her pregnancy. UPS required drivers to lift packages weighing up to 70 pounds, and it refused to allow Young to work while subject to the restriction. UPS had accommodation or reassignment policies for certain employees, including those injured on the job, covered by the ADA, or who lost DOT certification. Young remained on unpaid leave during much of her pregnancy and alleged that UPS unlawfully refused to accommodate her pregnancy-related lifting restriction.
Procedural history
Young filed a pregnancy-discrimination charge with the EEOC and later brought suit in the United States District Court for the District of Maryland after receiving a right-to-sue letter. The District Court granted UPS summary judgment, concluding that Young could not establish intentional discrimination or a prima facie case under McDonnell Douglas. The Fourth Circuit affirmed. The Supreme Court granted certiorari, vacated the judgment, and remanded.