Young v. United Parcel Service, Inc.
2013 U.S. App. LEXIS 26320
| 4th Cir. | 2013Background
- Pregnant employee Young sought light-duty accommodation but UPS restricted light duty to on-the-job injuries, ADA disabilities, and DOT-status losses; UPS lifting limit was 70 pounds (20 pounds for pregnancy) and inside-work options varied by policy; Young’s request occurred during 2006–2007 and she eventually gave birth and returned to work; district court granted UPS summary judgment on PDA and ADA claims after discovery; the appeal focused on ADA disability status and pregnancy discrimination under the PDA; district court treated pregnancy as not constituting a disability under the ADA and held UPS policy PDA-compliant.
- Young argued UPS regarded her as disabled and discriminated on pregnancy under PDA; UPS argued no disability and neutral policy; district court held no disability and no direct PDA violation, and granted summary judgment.
- Key policy features: light-duty not available to pregnancy; alternative light-duty provided for on-the-job injuries, ADA-disabled, or DOT-certificate-loss; no general accommodation for pregnancy.
- Young attempted to identify a comparator group (ADA-disabled, DOT-lost, on-the-job injury) to satisfy a prima facie case; such comparators were not properly situated under the PDA.
- Court outcome: affirmance of district court’s summary judgment for UPS on ADA and PDA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Young’s ADA claim fails for lack of disability | Young was regarded as disabled due to pregnancy-related limits | Young not disabled; policy-neutral regard to pregnancy | ADA claim fails; no disability proven |
| Whether UPS’s PDA policy violates the PDA | Policy excludes pregnant workers from light duty | Policy is neutral and not pregnancy-specific | Policy compliant with PDA; not direct pregnancy discrimination |
| Whether Williams’s comments show corporate animus | Williams’s statements reflect corporate bias | Not enough to show discriminator decisionmaker influence | Insufficient direct evidence of discrimination; not dispositive |
| Whether Young established a prima facie case under McDonnell Douglas | She is in a protected class and seeks favorable treatment | No appropriate comparator; lifting restriction not equivalent to ADA disability | No prima facie case; cannot show disparate treatment |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (United States Supreme Court 1973) (burden-shifting framework for Title VII discrimination)
- Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346 (4th Cir. 1996) (ADA/major life activities and disability definitions)
- Sutton v. United Air Lines, Inc., 527 U.S. 471 (U.S. Supreme Court 1999) (disability definition and major life activities)
- Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184 (U.S. Supreme Court 2002) (limits on what constitutes a disability)
- Urbano v. Cont’l Airlines, Inc., 138 F.3d 204 (5th Cir. 1998) (interpretation of PDA and pregnancy-related conditions)
- Ensley-Gaines v. Runyon, 100 F.3d 1220 (6th Cir. 1996) (analysis of PDA scope; debated interpretive impact)