Employment Litigation · Primary-source case analysis

Young v. UPS: The Pregnancy Accommodation Comparator Framework

By Aneeta Mishra and Timothy Chan

Published April 24, 2026

Young provides a proof structure for claims that an employer’s accommodation policy imposed a significant burden on pregnant employees without a sufficiently strong justification.

UPS denied a lifting accommodation

Peggy Young’s doctor restricted lifting during pregnancy. UPS did not permit her to work under that restriction even though it accommodated several categories of nonpregnant employees who could not perform the same lifting tasks.

The statute does not grant automatic preferred treatment

The Pregnancy Discrimination Act requires pregnant workers to be treated the same as other persons similar in their ability or inability to work. The Court rejected both an unconditional most-favored-nation rule and an approach that treated a facially neutral policy as conclusive.

Comparator evidence can show pretext

A plaintiff may establish a prima facie case by identifying accommodated nonpregnant employees with similar work limitations. She may then show that the employer’s reasons are not strong enough to justify the significant burden its policy places on pregnant workers.

Disposition

The Court vacated summary judgment for UPS and remanded for application of the announced framework. It did not decide that Young had already proved intentional discrimination.

Key takeaways

• Compare actual work limitations, not job labels alone.
• Inventory every category receiving light duty or other accommodation.
• Test whether the employer’s reasons explain the resulting burden.
• Preserve policy versions and accommodation records from the relevant period.