## Facts

- Linda Wimberly worked for J.C. Penney and took a pregnancy-related leave of absence granted “without guarantee of reinstatement.”
- When she sought to return, the employer stated no positions were available.
- Wimberly applied for Missouri unemployment benefits.
- Missouri denied benefits under a statute disqualifying claimants who voluntarily leave work without good cause attributable to the work or employer.
- The Labor and Industrial Relations Commission found Wimberly stopped working because of pregnancy and therefore fell within the voluntary-quit disqualification.
- State courts disagreed on whether the Missouri disqualification conflicted with FUTA’s requirement that states not deny compensation “solely on the basis of pregnancy.”

## Issues

1. Whether FUTA § 3304(a)(12) prohibits a state from applying a neutral voluntary-quit disqualification to a claimant who left work because of pregnancy.
2. Whether denial of benefits under such a neutral rule constitutes denial “solely on the basis of pregnancy” within the meaning of FUTA.

## Decision

- The Supreme Court affirmed the Missouri Supreme Court.
- FUTA § 3304(a)(12) was construed to prohibit states from singling out pregnancy for unfavorable treatment, not to require preferential treatment for pregnancy-related separations.
- Missouri’s voluntary-quit rule was deemed neutral because it disqualifies all claimants who leave for reasons not causally connected to work or the employer.
- The denial was based on the general voluntary-quit disqualification, not on pregnancy as an independent disqualifying category.

## Legal Principles

- FUTA § 3304(a)(12) forbids denial of unemployment compensation “solely on the basis of pregnancy or termination of pregnancy.”
- The statutory focus is on how the state treats pregnancy as a condition; a state violates FUTA when it singles out pregnancy for adverse treatment.
- A state may apply an evenhanded voluntary-quit disqualification to pregnancy-related job separations when the rule applies equally to other non-work-related reasons for leaving.
- Consistent administrative interpretation by the U.S. Department of Labor supporting equal (not preferential) treatment may reinforce this reading of FUTA.

## Conclusion

FUTA’s pregnancy provision bars discriminatory exclusions targeting pregnancy but permits states to deny benefits under neutral, generally applicable voluntary-quit rules when pregnancy is treated the same as other personal, non-work-related reasons for leaving employment.


Wimberly v. Lab. & Indus. Rels. Comm’n of Mo., 479 U.S. 511 (1987)