Young v. United Parcel Service, Inc., Dkt. No. 12-1226 (U.S. March 25, 2015).
Facts: After a female UPS employee became pregnant, her doctor restricted her from lifting more than 20 pounds. Because UPS required its drivers to be able to lift 70 pounds, UPS told the woman that she could not work while she was pregnant. The woman filed suit against UPS under Title VII, which prohibits sex discrimination “because of or on the basis of pregnancy, childbirth, or related medical conditions.” Apparently, UPS policy accommodated similar weight restrictions for those who suffered on-the-job injuries, those covered under the Americans with Disabilities Act (ADA), and those who had lost their Department of Transportation (DOT) certifications. According to UPS, pregnancy did not fall under any of those particular categories and so they could legitimately deny her the same accommodations. An appellate court upheld judgment in favor of UPS, but the employee appealed.
Holding: The Supreme Court reversed the judgment. A pregnant worker makes a prima facie case of discriminatory treatment under Title VII by showing that (1) she belongs to the protected class, (2) she sought accommodation, (3) the employer did not accommodate her, and (4) the employer did accommodate others “similar in their ability or inability to work.” The employer then may justify the refusal to accommodate with a legitimate, nondiscriminatory reason. According to the Court, that reason cannot consist of a claim that it is more expensive or less convenient to add pregnant women to the category of those whom the employer accommodates. An employee can overcome the employer’s stated reasons by providing evidence that the employer’s policies impose a significant burden on pregnant workers and the employer’s reasons are not strong enough to justify that burden. Evidence supporting an employee’s claims can include a showing that the employer accommodates a large percentage of nonpregnant workers while failing to accommodate a large percentage of pregnant workers. The record in this case created a genuine dispute as to whether UPS provided more favorable treatment to at least some nonpregnant employees. The Court returned the case to the appellate court to consider whether UPS’s stated reasons for refusing to accommodate the woman were a pretext for discrimination.
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