Young v. United Parcel Service

Young v. United Parcel Service, 575 U.S. 206 (2015), is a United States Supreme Court case that the Court evaluated the requirements for bringing a disparate treatment claim under the Pregnancy Discrimination Act. In a 6–3 decision, the Court held that to bring such a claim, a pregnant employee must show that their employer refused to provide accommodations and that the employer later provided accommodations to other employees with similar restrictions. The Court then remanded the case to the United States Court of Appeals for the Fourth Circuit to determine whether the employer engaged in discrimination under this new test.

Background

Pregnancy Discrimination Act

In 1978, the United States Congress passed the Pregnancy Discrimination Act, amending Title VII of the Civil Rights Act of 1964 to "prohibit sex discrimination on the basis of pregnancy," as a direct response to the Court's ruling in General Electric Company v. Gilbert. The Act mandates 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.” However, the Act provides exceptions for a "legitimate, nondiscriminatory, nonpretextual justification for these differences in treatment."

Initial lawsuit

In 2006, Peggy Young was working as a delivery driver for United Parcel Service when she requested time off in order to undergo in vitro fertilization. After becoming pregnant, Young's doctors advised her that "she should not lift more than 20 pounds during the first 20 weeks of her pregnancy or more than 10 pounds thereafter." United Parcel Service (UPS) requires that delivery drivers be able to lift parcels up to 70 pounds (150 pounds with assistance).