Young v. United Parcel Service, Inc.

Under Section VII of the Civil Rights Act of 1964 a pregnant worker pursuing a claim that an employer is in violation of the Act through disparate treatment can establish a prima facie case, under the analysis in McDonald Douglas Corp. v. Green, 411 U.S. 792., by showing she is a member of a protected class, she requested accommodation, the employer did not provide accommodation, and the employer accommodated others “similar in their ability to work.”

Petitioner was a pregnant employee of Respondent. During the course of Petitioner’s pregnancy she was advised by her doctor that she could not lift more than twenty pounds. Petitioner informed Respondent that she would be unable work under the twenty pound lifting restriction. Petitioner sought a disparate treatment claim under Section VII of the Civil Rights Act of 1964 and was able to produce evidence that Respondent had policies in place to accommodate workers who were injured on the job, were disabled under the Americans with Disabilities Act (ADA), and employees who had lost Department of Transportation certifications. The District Court granted Respondent’s motion for summary judgment under the reasoning that Petitioner and the groups of workers described were not “similarly situated comparator[s].” The Fourth Circuit affirmed the District Court’s grant of summary judgment.

The Court held that the under Section VII of the Civil Rights Act of 1964 a pregnant worker pursuing a claim that an employer is in violation of the Act through disparate treatment can establish a prima facie case, under the analysis in McDonald Douglas Corp. v. Green, 411 U.S. 792., by showing she is a member of a protected class, she requested accommodation, the employer did not provide accommodation, and the employer accommodated others “similar in their ability to work.” Petitioner attempted to argue that pregnancy discrimination should be categorized as a type of sexual discrimination, but the Court was not persuaded by the argument because the argument violates the congressional intent of the Pregnancy Discrimination Act which amended Section VII of the Civil Rights Act of 1964 to safeguard pregnant individuals from discrimination. The Court vacated the Fourth Circuit’s affirmation of summary judgment in favor of Respondent and remanded the case.