Young v. United Parcel Service, Inc.

March 25, 2015 · No. 12-1226

Plain-language summary

**Question presented** Did the Pregnancy Discrimination Act require United Parcel Service (UPS) to give a pregnant employee the same light‑duty accommodations that it gave other non‑pregnant workers with similar work‑ability limits, and could a pregnant worker prove discrimination by showing that UPS accommodated many non‑pregnant employees but not her? **Holding** The Supreme Court held that a pregnant worker may use the usual “McDonnell Douglas” burden‑shifting test to show discrimination, and that a plaintiff can point to the employer’s accommodations of other workers with similar limitations as evidence of a possible illegal disparity. Because the record showed a genuine dispute over whether UPS’s policy placed a significant burden on pregnant workers, the Court said the lower court’s summary‑judgment ruling was wrong and sent the case back to the Fourth Circuit for further fact‑finding. **Core reasoning (plain English)** *Majority* – Justice Breyer wrote that the Pregnancy Discrimination Act does **not** give pregnant employees a “most‑favored‑nation” guarantee that any accommodation offered to any non‑pregnant worker must automatically be offered to every pregnant worker. Instead, the law requires that pregnant workers be treated the same as **other workers who are similarly able or unable to work**. To prove discrimination, a pregnant employee can (1) show she belongs to the protected class, (2) show she asked for an accommodation, (3) show the employer refused, and (4) show the employer does give similar accommodations to non‑pregnant employees with comparable work restrictions. If the employer offers a legitimate, non‑discriminatory reason for the refusal, the employee can still win by showing that reason is a pretext—especially when the employer’s policy helps a large share of non‑pregnant workers but leaves a large share of pregnant workers untreated. Because such facts existed, the case could not be decided on summary judgment. *Dissent* – Justice Scalia, joined by Justices Kennedy and Thomas, argued that the Act’s language limits the comparison to “other persons” who are **not pregnant** and that Congress did not intend to force employers to extend every accommodation to pregnant workers. The dissent said the lower courts correctly applied the statute and that there was no genuine issue of fact—UPS’s policy was a lawful, neutral rule based on lifting ability, not an illegal discrimination. Therefore, the summary‑judgment decision should have stood. **Vote** The majority opinion was joined by Chief Justice Roberts and Justices Ginsburg, Sotomayor, and Kagan. Justice Alito wrote a concurring opinion (agreeing with the judgment but for different reasons). Justice Scalia filed a dissent, joined by Justices Kennedy and Thomas; Justice Kennedy also filed a separate dissent.
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