In its recent March 25, 2015 decision, the Supreme Court, in Young v. United Parcel Service, Inc. took the side of a former UPS driver. As a part-time driver for UPS, Peggy Young was required to be able to lift up to 70lbs; however, upon becoming pregnant in 2006, she was advised not to lift more than 20lbs throughout the course of the pregnancy.
Young requested an accommodation from UPS and was denied. In turn, she sued UPS under the Pregnancy Discrimination Act, alleging that similarly limited, but not pregnant employees of UPS were granted accommodations. The District Court found in favor of UPS, granting its motion for summary judgment, and the Fourth Circuit affirmed. However, the Supreme Court remanded the case, finding that pregnant workers can establish that an employer’s legitimate, non-discriminatory justifications are pretextual so long as the employer’s accommodations policies significantly burden pregnant workers and its justifications and reasoning are not sufficiently strong. As a result, Young will have a renewed opportunity to pursue her case in a more Plaintiff-friendly courtroom.
While this case is important, the reach of its holding is likely to be narrow and limited. This action was brought prior to the enactment of the 2008 amendments to the Americans with Disabilities Act (ADA). Those amendments expanded and clarified the scope and meaning of disability under the ADA, so cases like Young are far less likely to gain any traction. While the holding may be narrow, it is important for employers to recognize that the Court in Young readjusted the McDonnell Douglas burden shifting-framework, providing plaintiffs with more of an opportunity to advance beyond the summary judgments stages and have their case heard in front of a jury. Therefore, should a similar case gain any momentum, the employer is more likely to now find itself in front of a jury. Finally, while the Supreme Court holding did fall on the side of Peggy Young, it is still for the lower court to decide whether or not she can move beyond summary judgment under the newly set forth standard.
