Young v. United Parcel Service, Inc., 135 S. Ct. 1338

Background

Peggy Young, a part‑time UPS driver, had a pregnancy‑related lifting restriction from her doctor and was told she could not work under UPS’s 70‑pound lifting requirement; she lost pay and benefits while off work.
Young sued under the Pregnancy Discrimination Act (PDA), claiming UPS accommodated other employees with similar work limitations but denied comparable accommodation to pregnant workers.
UPS had multiple accommodation categories in its labor agreement/policies: on‑the‑job injuries (light duty), ADA‑covered disabilities, and reassignment for loss of DOT certification; UPS argued Young did not fall into those categories.
District Court granted summary judgment to UPS; the Fourth Circuit affirmed, finding Young not similarly situated to accommodated nonpregnant employees and that UPS’s pregnancy‑blind policy was facially neutral.
The Supreme Court granted certiorari to resolve how §2000e(k)’s command that pregnant women be treated the same “as other persons … similar in their ability or inability to work” applies when employers accommodate some nonpregnant workers but not pregnant workers.
The Supreme Court vacated and remanded, holding that a pregnant plaintiff may proceed under McDonnell Douglas to show disparate treatment, and may defeat summary judgment by showing the employer’s policies impose a significant burden on pregnant workers and that the employer’s justifications are not sufficiently strong.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of §2000e(k): who are the relevant comparators?	Young: pregnant workers must get the same accommodations as nonpregnant workers with similar ability/inability to work regardless of the cause of the limitation.	UPS: §2000e(k) only clarifies that pregnancy is sex discrimination; compare pregnant workers with nonpregnant workers within the same neutral accommodation category.	The Court rejects both extremes: comparators are those "other persons" similar in ability/inability to work, but courts must evaluate context and employer justifications under disparate‑treatment principles.
Appropriate legal framework to prove discrimination under PDA	Young: automatic entitlement where employer accommodates any subset of disabled workers but excludes pregnant workers (no McDonnell Douglas needed).	UPS: treat pregnancy as added protected trait only; must show discriminatory intent like ordinary Title VII disparate‑treatment claims.	Use McDonnell Douglas burden‑shifting for disparate‑treatment claims; plaintiff may make prima facie showing by comparing treatment to others similar in ability/inability to work.
Role of employer justifications and neutrality of policies	Young: categorical exclusion of pregnant workers from accommodations unlawful irrespective of neutral business reasons.	UPS: facially neutral policies that distinguish by source of limitation (e.g., on‑the‑job injuries) are permissible.	Employer can proffer legitimate, nondiscriminatory reasons; but reasons that merely assert cost or convenience likely insufficient where policies impose a significant burden on pregnant workers and the justifications are weak — jury may infer intentional discrimination.
Standard for surviving summary judgment	Young: evidence that UPS accommodated many nonpregnant workers but not pregnant workers is dispositive.	UPS: Young is not similarly situated to accommodated workers; summary judgment proper.	Vacated and remanded: viewing evidence favorably to Young, there is a genuine dispute as to whether comparators exist and whether UPS’s reasons are pretextual; Fourth Circuit must reassess under Court’s test.

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for disparate‑treatment claims)
Burdine v. Texas Dept. of Community Affairs, 450 U.S. 248 (1981) (plaintiff’s prima facie burden is not onerous; employer must articulate legitimate nondiscriminatory reason)
Raytheon Co. v. Hernandez, 540 U.S. 44 (2003) (liability in disparate‑treatment cases depends on whether protected trait motivated the decision)
Trans World Airlines, Inc. v. Thurston, 469 U.S. 111 (1985) (direct evidence vs. burden‑shifting approaches)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (circumstantial evidence can permit inference of intentional discrimination)
Teamsters v. United States, 431 U.S. 324 (1977) (pattern‑or‑practice and disparate‑impact doctrines)
Furnco Constr. Corp. v. Waters, 438 U.S. 567 (1978) (McDonnell Douglas prima facie rules are flexible)
General Elec. Co. v. Gilbert, 429 U.S. 125 (1976) (pre‑PDA holding that pregnancy exclusion from disability plan was not sex discrimination)
California Fed. Sav. & Loan Assn. v. Guerra, 479 U.S. 272 (1987) (PDA intended to overrule Gilbert’s reasoning)
Skidmore v. Swift & Co., 323 U.S. 134 (1944) (weight to agency interpretations depends on persuasiveness)
AT&T Corp. v. Hulteen, 556 U.S. 701 (2009) (discusses PDA’s relationship to prior decisions)