## Facts

- Peggy Young worked as a part-time delivery driver for United Parcel Service (UPS) in Maryland.
- After becoming pregnant in 2006, Young’s medical providers imposed lifting restrictions (20 pounds initially, then 10 pounds).
- UPS required drivers to be able to lift up to 70 pounds (and up to 150 pounds with assistance).
- Under a collective-bargaining-based policy, UPS provided light duty/accommodations to certain employees, including (1) those injured on the job, (2) those who lost Department of Transportation certification, and (3) those with impairments covered by the ADA.
- UPS denied Young an accommodation because pregnancy-related restrictions did not fit within those categories, placed her on unpaid leave, and she lost medical coverage during that period.
- Young returned to work after giving birth in 2007.
- Young sued under Title VII as amended by the Pregnancy Discrimination Act (PDA), asserting a disparate-treatment claim based on denial of accommodation.
- The district court granted summary judgment to UPS, and the Fourth Circuit affirmed, treating UPS’s policy as facially neutral and “pregnancy-blind.”

## Issues

1. When an employer accommodates some nonpregnant employees with work limitations, under what circumstances does the PDA require comparable accommodations for pregnant employees “similar in their ability or inability to work”?
2. How should courts apply the McDonnell Douglas disparate-treatment framework to PDA accommodation claims, including what constitutes a prima facie case and sufficient evidence of pretext?

## Decision

- The Supreme Court vacated the Fourth Circuit’s judgment and remanded.
- The Court rejected both (a) the view that pregnant workers are automatically entitled to any accommodation offered to any nonpregnant worker and (b) the view that a facially neutral policy always satisfies the PDA even if it accommodates many nonpregnant workers while excluding many pregnant workers.
- The Court held Young produced enough evidence to create a genuine dispute of material fact under the proper standard; summary judgment for UPS was inappropriate.

## Legal Principles

- The PDA’s second clause requires comparing treatment of pregnant employees to nonpregnant employees “similar in their ability or inability to work,” but it does not make pregnancy a “most-favored” status requiring every accommodation given to any other worker.
- PDA disparate-treatment claims generally proceed under McDonnell Douglas.
- A pregnant plaintiff may establish a prima facie case by showing: (1) protected status, (2) request for accommodation, (3) denial of accommodation, and (4) accommodation of others similar in their ability or inability to work.
- The employer must then offer legitimate, nondiscriminatory reasons; those reasons cannot be merely that accommodating pregnancy is more expensive or less convenient.
- At the pretext stage, a plaintiff may reach a jury by showing the policy imposes a significant burden on pregnant workers and the employer’s reasons are not sufficiently strong to justify that burden, supporting an inference of intentional discrimination.
- Evidence that an employer accommodates a large percentage of nonpregnant workers while failing to accommodate a large percentage of pregnant workers can support an inference of a significant burden.

## Conclusion

The Court required lower courts to apply a comparator-focused McDonnell Douglas analysis to PDA accommodation claims and allowed plaintiffs to survive summary judgment by showing that an accommodation scheme significantly burdens pregnant workers without a sufficiently strong, nonpretextual justification.


Young v. United Parcel Serv., Inc., 575 U.S. 206 (2015)