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Young v. UPS

Supreme Court of the United States

December 3, 2014, Argued; March 25, 2015, Decided

No. 12-1226

Case Summary

Overview

HOLDINGS: [1]-A plaintiff alleging that an accommodation denial was disparate treatment under 42 U.S.C.S. § 2000e(k)'s second clause made out a prima facie case by showing that she belonged to the protected class and sought accommodation, and that the employer did not accommodate her, but accommodated others similar in ability or inability to work; [2]-If a plaintiff made out a prima facie case, the employer justified a refusal to accommodate by relying on legitimate, nondiscriminatory reasons; [3]-If the employer offered legitimate, nondiscriminatory reasons, a plaintiff had to show that the proffered reasons were pretextual; [4]-The lower courts improperly granted an employer summary judgment where a pregnant employee's evidence created a genuine dispute as to whether the employer provided more favorable treatment to at least some employees whose situation could not be distinguished.

Outcome

Judgment vacated; case remanded. 6-3 decision; 1 concurrence; 2 dissents.

LexisNexis® Headnotes

 

 

Labor & Employment Law > ... > Disparate Treatment > Statutory Application > General Overview

Labor & Employment Law > ... > Gender & Sex Discrimination > Scope & Definitions > Parental Rights & Pregnancy

HN1 The Pregnancy Discrimination Act makes clear that Title VII of the Civil Rights Act of 1964’s prohibition against sex discrimination applies to discrimination based on pregnancy. It also says that employers must treat women affected by pregnancy the same for all employment-related purposes as other persons not so affected but similar in their ability or inability to work. 42 U.S.C.S. § 2000e(k).

 

Labor & Employment Law > ... > Disparate Treatment > Evidence > Burdens of Proof

Labor & Employment Law > ... > Disparate Treatment > Statutory Application > General Overview

Labor & Employment Law > ... > Gender & Sex Discrimination > Scope & Definitions > Parental Rights & Pregnancy

HN2  Burdens of Proof

The Pregnancy Discrimination Act requires courts to consider the extent to which an employer’s policy treats pregnant workers less favorably than it treats nonpregnant workers similar in their ability or inability to work. And in all cases in which an individual plaintiff seeks to show disparate treatment through indirect evidence, it requires courts to consider any legitimate, nondiscriminatory, non-pretextual justification for these differences in treatment. Ultimately the court must determine whether the nature of the employer’s policy and the way in which it burdens pregnant women shows that the employer has engaged in intentional discrimination.

 

Labor & Employment Law > ... > Disparate Treatment > Statutory Application > General Overview

Labor & Employment Law > Discrimination > Disparate Treatment > Scope & Definitions

Labor & Employment Law > ... > Gender & Sex Discrimination > Scope & Definitions > Parental Rights & Pregnancy

HN3 The first clause of the Pregnancy Discrimination Act specifies that Title VII of the Civil Rights Act of 1964’s term "because of sex" includes because of or on the basis of pregnancy, childbirth, or related medical conditions. 42 U.S.C.S. § 2000e(k). The second clause says that women affected by pregnancy, childbirth, or related medical conditions shall be treated the same for all employment-related purposes as other persons not so affected but similar in their ability or inability to work.

 

Labor & Employment Law > ... > Evidence > Burdens of Proof > Burden Shifting

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135 S. Ct. 1338 ; 191 L. Ed. 2d 279 ; 2015 U.S. LEXIS 2121 ; 83 U.S.L.W. 4196; 126 Fair Empl. Prac. Cas. (BNA) 765; 98 Empl. Prac. Dec. (CCH) P45,276; 91 Fed. R. Serv. 3d (Callaghan) 507; 25 Fla. L. Weekly Fed. S 155

PEGGY YOUNG, Petitioner v. UNITED PARCEL SERVICE, INC.

Notice: The LEXIS pagination of this document is subject to change pending release of the final published version.

Subsequent History: On remand at, Remanded by Young v. UPS, 2015 U.S. App. LEXIS 7695 (4th Cir., Apr. 28, 2015)

Prior History:  [1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

Young v. UPS, 784 F.3d 192 (4th Cir. Md., 2013)

Disposition: Vacated and remanded.