Law School Case Brief
Cal. Fed. Sav. & Loan Ass'n v. Guerra - 479 U.S. 272, 107 S. Ct. 683 (1987)
In determining whether a state statute is pre-empted by federal law and therefore invalid under the Supremacy Clause of the Constitution, the sole task is to ascertain the intent of Congress. Federal law may supersede state law in several different ways. First, when acting within constitutional limits, Congress is empowered to pre-empt state law by so stating in express terms. Second, congressional intent to pre-empt state law in a particular area may be inferred where the scheme of federal regulation is sufficiently comprehensive to make reasonable the inference that Congress left no room for supplementary state regulation. Neither of these bases for pre-emption exists when Congress has explicitly disclaimed any intent categorically to pre-empt state law or to "occupy the field" of employment discrimination law. 42 U.S.C.S. §§ 2000e-7 and 2000h-4.
The California Fair Employment and Housing Act in § 12945(b)(2) requires employers to provide leave and reinstatement to employees disabled by pregnancy. Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination on the basis of sex, as amended by the Pregnancy Discrimination Act (PDA), specifies that sex discrimination includes discrimination on the basis of pregnancy. A woman employed as a receptionist by petitioner California Federal Savings & Loan Association (Cal Fed) took a pregnancy disability leave in 1982, but when she notified Cal Fed that she was able to return to work she was informed that her job had been filled and that there were no similar positions available. She then filed a complaint with respondent Department of Fair Employment and Housing, which charged Cal Fed with violating § 12945(b)(2). Before a hearing was held on the complaint, Cal Fed, joined by the other petitioners, brought an action in federal district court, seeking a declaration that § 12945(b)(2) was inconsistent with and pre-empted by Title VII and an injunction against its enforcement. The district court granted summary judgment for petitioners, but the United States Court of Appeals for the Ninth Circuit reversed.
Did Title VII of the Civil Rights Act of 1964, as amended by the Pregnancy Discrimination Act of 1978, pre-empt a state statute that required employers to provide leave and reinstatement to employees disabled by pregnancy?
In affirming the judgment that the state statute was not pre-empted, the Supreme Court of the United States held that it did not compel employers to treat pregnant workers better than other disabled workers, but merely established minimum benefits to be provided to pregnant workers. The state statute was not inconsistent with the purposes of the federal statute, nor did it require the doing of an act that was unlawful under Title VII.
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