Young v. United States Parcel Service

By Andrea De Leon

In Young v. United States Parcel Service, Inc., the Supreme Court of the United States was tasked with deciding whether the Pregnancy Discrimination Act (PDA) requires an employer to provide the same work accommodations to an employee with pregnancy-related work limitations as to employees with similar, but not pregnancy-related, work limitations. Peggy Young, a UPS delivery driver, was required to lift up to 70 pounds, but when she became pregnant her doctor instructed her to restrict her lifting to 20 pounds. UPS did not accommodate her via their “light duty policy,” which provided accommodations to employees who suffered on-the-job injuries or were covered under the ADA. The framework established in McDonnell Douglas Corp. v. Green requires evidence that the employer’s actions were more likely than not based on discriminatory motivation, and that any business reasons the employer provides are pretextual. The Court in Young held that the McDonnell Douglas framework must be applied to Young’s claims while expanding the pretext portion of the analysis to say that plaintiffs such as Young are no longer required to show that the employer’s policy rationale was intentionally biased. The employee can instead satisfy the burden of showing pretext by demonstrating that the policy at issue put a significant burden on pregnant employees and that the employer’s business reason did not justify that burden.

See Young v. United Parcel Service, No. 12-1226, slip op. (U.S. March 25, 2015).; McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).