California Federal Sav. & Loan Ass'n v. Guerra

479 U.S. 272

 

RULE:

Cal. Govt. Code § 12945(b)(2) does not compel California employers to treat pregnant workers better than other disabled employees; it merely establishes benefits that employers must, at a minimum, provide to pregnant workers.

FACTS:

Cal. Gov't. Code § 12945(b)(2) required that employers reinstate women after a reasonable pregnancy disability leave, and plaintiff employers and organizations challenged its application, claiming that Title VII of the Civil Rights Act of 1964, as amended by the Pregnancy Discrimination Act of 1978, pre-empted the state statute.

ISSUE:

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?

ANSWER:

No.

CONCLUSION:

The judgment of the appellate court was affirmed because in enacting the PDA, Congress did not intend to prohibit all favorable treatment of pregnancy. In affirming the judgment that the state statute was not pre-empted, the Court 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. Employers are free to give comparable benefits to other disabled employees, thereby treating women affected by pregnancy no better than other persons not so affected but similar in their ability or inability to work. The 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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