Young v. United Parcel Service, Inc.
784 F.3d 192
4th Cir.2013Background
- PDA amended Title VII to prohibit pregnancy-based discrimination and require similar treatment for pregnant and nonpregnant employees with similar abilities to work.
- UPS policy provides light duty only to on-the-job injuries, ADA disabilities, and DOT-certification losses; pregnancy lifting limits (20 pounds) do not qualify for light duty.
- Young, a long-time UPS air driver, became pregnant in 2006 and sought to return to work with lifting restrictions.
- UPS, relying on Mamlenski/Shawl notes and policy, determined Young could not perform essential functions and rejected light duty accommodations.
- Young remained on extended leave, later returned after giving birth, and later filed EEO charges alleging pregnancy, sex, race discrimination and disability claims.
- District court granted summary judgment for UPS on PDA and ADA claims; this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did UPS regard Young as disabled under the ADA? | Young argues UPS perceived disability due to pregnancy-related limits. | UPS relied on objective medical notes; no evidence of actual disability or mistaken belief. | No disabled perception; no genuine disability regarded. |
| Does UPS policy violate the PDA by not providing light duty to pregnant workers while accommodating others? | PDA requires treating pregnant employees the same as similarly situated nonpregnant workers. | Policy is neutral and pregnancy-blind; comparable accommodations exist for other categories. | Policy not direct evidence of pregnancy discrimination; PDA not violated. |
| Can Young establish a prima facie case of pregnancy discrimination under McDonnell Douglas? | Young is protected; she was denied accommodation; similarly situated nonpregnant comparators received better treatment. | Comparators are not similarly situated; pregnancy-lifting restriction is not equivalent to ADA or in-job injury statuses. | Prima facie case failed; no similarly situated comparators or genuine inference of discrimination. |
Key Cases Cited
- Int'l Union, United Auto., Aerospace & Agricultural Implement Workers of Am. v. Johnson Controls, 499 U.S. 187 (1991) (second PDA clause requires pregnancy to be treated like similarly situated nonpregnant employees)
- Newport News Shipbuilding & Dry Dock Co. v. EEOC, 462 U.S. 669 (1983) (pregnancy-related conditions within protected class; avoid treating pregnancy more favorably)
- Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999) (regarded-as disability concept; major life activities and perception by employer)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
- Ensley-Gaines v. Runyon, 100 F.3d 1220 (6th Cir. 1996) (interpretation of PDA second clause in some contexts; insufficient adoption here)