Employment Litigation · Primary-source case analysis

Young: Pregnancy-Accommodation Claims Turn on Comparable Work Limitations

Decision: Supreme Court of the United States, No. 12-1226, decided March 25, 2015. Document: Published United States Reports opinion.

Young v. United Parcel Service, Inc. reviewed a light-duty policy that accommodated several categories of workers but excluded a pregnant employee with a lifting restriction.

The comparison focuses on work ability

A claimant may identify nonpregnant employees who were similar in their ability or inability to work and nevertheless received accommodation.

The employer must articulate a legitimate reason

The reason ordinarily must be more than the cost or inconvenience of extending accommodation to pregnant employees.

A significant burden can support pretext

Evidence that a policy accommodates many nonpregnant workers while burdening many pregnant workers may permit an inference of intentional discrimination.

The summary-judgment record required reconsideration

The Court remanded for application of the clarified Pregnancy Discrimination Act framework.

Key takeaways

Discuss the procedural record

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