## Facts

- California’s Fair Employment and Housing Act required covered employers to provide a reasonable leave of absence for employees disabled by pregnancy, childbirth, or related medical conditions.
- The statute required reinstatement to the prior position (or a comparable one) upon return from pregnancy disability leave, absent business necessity; the enforcing agency interpreted this to require a reasonable, good-faith effort to place the employee in a substantially similar job if the original job no longer existed.
- Lillian Garland, a receptionist employed by California Federal Savings & Loan Association, took pregnancy disability leave.
- When Garland notified the employer she could return, the employer stated her job had been filled and no similar positions were available.
- Garland filed an administrative complaint; the state agency charged the employer with violating the pregnancy leave and reinstatement provision.
- The employer and other employers filed a federal action asserting the California requirement was inconsistent with, and preempted by, Title VII as amended by the Pregnancy Discrimination Act (PDA).

## Issues

1. Whether Title VII, as amended by the PDA, preempts a state law that mandates pregnancy disability leave and job reinstatement rights.
2. Whether the PDA’s equal-treatment requirement forbids a state from requiring pregnancy-specific benefits that are more favorable than those provided to other temporarily disabled employees.

## Decision

- The Supreme Court affirmed the judgment upholding the California statute.
- The Court held the state law was not preempted because it did not require conduct unlawful under Title VII/PDA and did not obstruct Congress’s objectives.
- The Court found no direct conflict because employers could comply with both federal nondiscrimination requirements and the state’s additional pregnancy protections.
- The Court rejected a “most-favored-nation” reading of the PDA that would bar any pregnancy-specific benefit beyond parity with other disabilities.
- A dissent would have found preemption on the theory that pregnancy-specific leave and reinstatement preferences conflict with the PDA’s equal-treatment command.

## Legal Principles

- Preemption analysis turns on congressional intent; absent clear intent to displace state regulation, state employment protections may coexist with federal antidiscrimination law.
- A state law is not preempted where compliance with both state and federal requirements is possible and the state law does not require an act prohibited by federal law.
- Title VII/PDA establishes a baseline guarantee against pregnancy discrimination; it does not bar states from granting additional pregnancy-related employment protections consistent with Title VII’s purposes.
- States may provide more protective employment standards than federal law so long as those standards do not conflict with federal statutory objectives or commands.

## Conclusion

The Court held that California’s requirement of job-protected pregnancy disability leave and reinstatement was compatible with Title VII as amended by the PDA, because the federal scheme sets minimum nondiscrimination protections and does not preempt consistent state measures that provide greater protection for pregnant workers.


Cal. Fed. Sav. & Loan Ass’n v. Guerra, 479 U.S. 272 (1987)