
Young v. United Parcel Service, Inc was a landmark pregnancy discrimination case that made its way to the US Supreme Court. The case involved Peggy Young, a UPS driver who was forced to take a leave of absence after becoming pregnant with her second child.
Young was told by her doctor that she should not lift heavy packages due to her pregnancy, but UPS's policy at the time required drivers to be able to lift packages up to 70 pounds. The policy was in place to ensure the safety of both drivers and customers.
Peggy Young was not alone in her struggles; many pregnant women face similar challenges in the workforce due to outdated policies and lack of accommodations.
Case Details
In 1999, United Parcel Service (UPS) hired Peggy Sue Young, who started driving their delivery trucks in 2002. Young drove part-time for UPS's early morning routes in Landover, Maryland from 2006 onward.
Young became pregnant in 2006 and requested to continue her leave after undergoing in vitro fertilization. UPS informed her that company policy wouldn't permit her to continue working because all drivers must be able to lift heavy objects.
Young's medical leave expired in November 2006, and she went on extended leave without pay or health insurance. She didn't return to work until after giving birth on April 29, 2007.
Facts
Peggy Young worked as a part-time driver for UPS from 2002 onwards, driving early morning routes in Landover, Maryland.
In July 2006, UPS granted Young a leave of absence for in vitro fertilization, but she soon became pregnant and requested to continue her leave.
Young's doctor advised her not to lift more than 20 pounds during the first 20 weeks of her pregnancy and no more than 10 pounds thereafter.
UPS required drivers to lift up to 70 pounds and refused to accommodate Young's lifting restriction.

Young argued that UPS accommodated other employees with similar work limitations, such as those injured on the job, those covered by the Americans with Disabilities Act, and those who lost their Department of Transportation certifications.
Young's medical leave expired in November 2006, and she went on extended leave without pay or health insurance.
Young did not return to work until after she gave birth on April 29, 2007.
In July 2007, Young filed a complaint with the Equal Employment Opportunity Commission, alleging discrimination under the Pregnancy Discrimination Act and the Americans with Disabilities Act.
UPS granted Young a leave of absence in July 2006, but she soon became pregnant and requested to continue her leave.
Issue
In Young v. United Parcel Serv., Inc., the main issue was whether the Pregnancy Discrimination Act requires an employer to provide the same accommodations to pregnant employees as it does to non-pregnant employees who are similar in their ability or inability to work. This issue is crucial because it affects how employers treat pregnant workers.

Peggy Young, a part-time driver for UPS, became pregnant in 2006 and was advised by her doctor not to lift more than 20 pounds during the first 20 weeks of her pregnancy. Young's doctor also stated that she couldn't lift more than 10 pounds thereafter.
UPS required drivers to lift up to 70 pounds and refused to accommodate Young's lifting restriction. This refusal resulted in Young taking unpaid leave and losing her medical benefits during her pregnancy.
Pregnancy Discrimination Act
The Pregnancy Discrimination Act (PDA) is a key aspect of the Young v. UPS case. It was adopted by Congress to prevent pregnancy discrimination in the workplace.
The PDA aimed to protect female employees from being treated differently from other employees simply because of their capacity to bear children. This means that employers should not discriminate against pregnant women.
In support of Young, pro-life organizations argue that a finding for UPS will erode the rights of women in the workplace. They believe that women will feel economically pressured into aborting their pregnancies.

The American Civil Liberties Union argues that a lack of pregnancy-accommodation policies prevent women from having the opportunity to fairly compete with men in the workplace. This is a significant concern, as it can impact women's careers and opportunities.
The Equal Employment Advisory Council and the National Federation of Independent Business argue that a finding for Young will give women preferential treatment in the workplace. They claim that this is not what Congress intended with the PDA.
Supreme Court Decision
The Supreme Court decision in Young v. United Parcel Service was a significant one, as it clarified the extent to which employers must accommodate pregnant employees under the Pregnancy Discrimination Act.
The Court applied the McDonnell Douglas framework, which requires employers to treat pregnant workers the same as non-pregnant workers who are similar in their ability or inability to work.
Young argued that UPS must provide pregnant employees with the same accommodations as non-pregnant employees receive for other injuries and disabilities, but the Court ultimately decided that refusing to accommodate pregnant employees solely based on cost or convenience is not a legitimate reason.
575 U.S. 206 (2015)

In 2015, the Supreme Court made a significant decision in the case of 575 U.S. 206.
The case involved a challenge to the Affordable Care Act's requirement that individuals purchase health insurance or pay a penalty. This requirement was a central aspect of the law, known as the individual mandate.
The Court ultimately upheld the individual mandate, ruling that it was constitutional under Congress's power to regulate interstate commerce. This decision had significant implications for the future of the Affordable Care Act.
The ruling was a 5-4 decision, with the majority opinion written by Chief Justice John Roberts.
Supreme Court Decision
The Supreme Court has made a significant decision regarding the Pregnancy Discrimination Act. The Court ruled that employers must treat pregnant workers the same as non-pregnant workers who are similar in their ability or inability to work.
The Court applied the McDonnell Douglas framework to establish a prima facie case of discrimination, which requires a plaintiff to show she belongs to the protected class, sought accommodation, was not accommodated, and that the employer accommodated others similar in their ability to work.

Refusing to accommodate pregnant employees solely based on cost or convenience is not a legitimate reason, according to the Court. This means employers can't just say it's too expensive or inconvenient to provide accommodations to pregnant workers.
The Court concluded that Young had shown a genuine dispute about whether UPS's policies imposed a significant burden on pregnant workers, requiring further proceedings to determine if the policies were pretextual. This indicates that the Court is taking a closer look at the impact of employers' policies on pregnant workers.
Important Questions Remain
The Young v. UPS decision is a significant victory for pregnant workers, but it doesn't provide clear answers to all the questions. The Supreme Court's balancing test leaves multiple questions to be worked out in the lower courts.
The key question posed by the Court in Young v. UPS is "Why, when an employer accommodated so many, could it not accommodate pregnant women as well?" This question highlights the uncertainty surrounding the Court's decision.
The Court held that an employer cannot refuse to accommodate pregnant workers simply because it "is more expensive or less convenient" to do so. This sets a new standard for employers to follow, but it's unclear how this will play out in practice.
Pregnant workers may still face significant barriers in the workplace, and the Court's decision may not provide enough protection. The Young decision is a step in the right direction, but it's far from a complete solution.
Frequently Asked Questions
Who won Young V UPS?
In Young v. UPS, the Supreme Court ruled in favor of the company with a 6-3 decision. The Court's majority opinion, delivered by Justice Breyer, upheld a narrower interpretation of the Pregnancy Discrimination Act.
Sources
- https://supreme.justia.com/cases/federal/us/575/206/
- https://studicata.com/case-briefs/case/young-v-united-parcel-serv-inc/
- https://www.dorsey.com/newsresources/publications/2015/03/supreme-court-issues-decision-in-iyoung-v-upsi-a__
- https://digitalcommons.law.lsu.edu/faculty_scholarship/389/
- https://www.uschamber.com/cases/discrimination/young-v-united-parcel-service
- https://www.law.cornell.edu/supct/cert/12-1226
- https://scholar.smu.edu/law_faculty/1048/
- https://nwlc.org/resource/young-v-ups-what-it-means-for-pregnant-workers/
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