Peggy Young V. United Parcel Service Inc Summary

The petitioner in Peggy Young vs. United Parcel Service Inc. was Peggy Young, while United Parcel Service Inc. (UPS) was the respondent. Peggy worked for the respondent as a part-time driver; her role involved picking up packages from the airport and delivering them to the company’s premises. Consequently, Peggy’s doctor warned her against lifting loads exceeding 20 pounds within the first five months of pregnancy; she was also cautioned not to lift loads exceeding 10 pounds thereafter. Unfortunately, UPS expected drivers such as Peggy to lift parcels weighing up to 70 pounds without assistance, and up to 150 pounds when assisted; therefore, they informed Peggy that she could not work under the lifting restrictions (Legal Information Institute). The company argued that Peggy’s situation was an “off-work” incident. Peggy had to go onto unpaid leave for most of her gestation period, and later lost her UPS medical insurance cover.
In 2007, Peggy launched a federal lawsuit with the Equal

Employment Opportunity Commission (EEOC) and later sued UPS in the United States District Court for the District of Maryland for pregnancy discrimination. Peggy argued that despite UPS denying her request for accommodation to take light duties, it often accommodated other employees who required lighter duties due to disability under the Americans with Disability Act. She added that UPS also granted light duty requests when other employees sustained on-the-job injuries, and when they lost their drivers’ licenses due to being convicted for D.W.I. In court, UPS argued that its Human Resources policies did not single out pregnant women, conditions due to “off-work” events.

The Legal Issue
The major legal issue in Peggy Young vs. United Parcel Service Inc. related to the court’s decision over whether Young was subject to pregnancy discrimination in breach of the Pregnancy Discrimination Act (PDA) and the Americans with Disabilities Act (ADA). The case first got the attention of the United States District Court when it granted a summary of judgment to UPS without proceeding to full trial. The court concluded that inter alia (among others) Peggy could not prove expressly and beyond reasonable doubt (prima facie), under McDonnell Douglas, that there was a discrimination case. The court added that the colleagues on whom Peggy based her argument had great qualifications under the on-the-job (when execute duties), American Disability Act and Department of Transport that she could compare her situation.
The District Court referred the case to the Court of Appeal for the Fourth Circuit to declare whether there existed in Young’s case “a genuine issue of material fact as to whether UPS’ reasons for having treated Young less favorably than these other non-pregnant employees were pretextual” (Legal Information Institute). The judges in this court upheld the views of the previous court. In particular, the Fourth Circuit of Appeal held that “an individual pregnant worker who seeks to show disparate treatment through indirect evidence may do so through the application of the McDonnell Douglas framework Pp. 1348-1356” (Legal Information Institute). Additionally, the Appeals Court determined that UPS’ failure to accommodate the pregnancy at a time when it accommodated the needs of others with a similar limitation of their abilities did not constitute an act of pregnancy discrimination. The Pregnancy Disability Act of 1978 requires that employers handle pregnant employees in the same manner as their non-pregnant colleagues with a similar inability or ability to execute their duties (National Women Law Center). While interpreting this part of the law, the Court of Appeal argued that the resilience of UPS regarding their rules on the accommodation of workers with particular conditions, while excluding pregnant women, did not amount to a violation of the law; they considered that Peggy did not prove that the rules displayed an intent to mistreat pregnant women.
As the case required further clarification, the Court of Appeal Fourth Circuit moved it to the Supreme Court. The Supreme Court made the final decision on the case, with the judges explaining their individual standings. The court argued the case on December 3, 2014 and decided it on March 25, 2015. The federal case presented to the Supreme Court was for it to determine whether “the Pregnancy Discrimination Act (PDA) 1978 required that employers accommodate a pregnant employee in the same manner that they would accommodate a non-pregnant employee who had similar limitations to work but pregnancy unrelated” (National Women Law Center).

Judicial Opinions
Since the case was effectively determined at the Supreme Court, only the opinions of its judges are significant here.

The majority group, whose ruling settled matters, included Breyer, Roberts, Ginsburg, Sotomayor, Kagan, and Alito. The minority dissenting group included Scalia, Kennedy, and Thomas. The majority held that Peggy Young was right, and gave a sufficient explanation of her claim of pregnancy discrimination. The court overturned the District Court and the Court of Appeal Fourth Circuit, indicating that both erred in their decisions. Justice Breyer read out the opinion held by the court that Title VII of the Pregnancy Discrimination Act is clear on the prohibition of sex discrimination, which applies to pregnancy-based discrimination. The law states that: “employers must treat women affected by pregnancy... the same for all employment-related purposes… as other persons not so affected but similar in their ability or inability to work” (Legal Information

Institute).
The court further determined that Congress, in express language and through the Pregnancy Discrimination Act (PDA) 1978, had the intention to compel employers to provide equal treatment to workers having medical needs due to pregnancy as other workers who have similar needs due to injury, disease, or disability. The court interpreted that Congress passed the PDA in response to the decision of the Supreme Court in General Electric Company vs. Gilbert, 429 U.S. 125. 135-140, 97 S. Ct. 401, 50 L. Ed. 2d 343 (1976). In addition, the Supreme Court made reference to the fourth title of the Civil Rights Act 1964, which prohibits covered employers from “discriminat(ing) against any individual with respect to… terms, conditions, or privileges of employment, because of such individual’s sex” (Legal Information Institute). Before making the closing statements on the case, the court clarified that in the judges’ view, the Act called for the court’s consideration of the extent to which the policy of the employer (UPS) treats pregnant women in less favorable ways, when compared to non-pregnant workers with similar abilities or inabilities.
The court added that in the Peggy v. UPS case, where the plaintiff wanted to prove disparate treatment using indirect evidence, the Act required the court’s consideration of any legitimate, nonpretextual, and nondiscriminatory justification of the differences in treatment. At this point, the court referred to the case laws of McDonnell Douglas Corp. vs. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 K.Ed.2d 668. The Court argued that under case law, “the plaintiff has the initial burden of establishing a prima facie case of discrimination” (Legal Information Institute). The court further stated that the PDA required courts to ultimately determine whether the design of the employer’s policy, and the way in which pregnant women were burdened, demonstrated that the employer intentionally discriminated against pregnant women. The court then ruled: “Given our view of the law, we must vacate that court’s judgment” (Legal Information Institute). This statement means that they overturned the grant of summary that the Court of Appeal affirmed in favor of UPS.
In dissenting, Justices Scalia, Kennedy, and Thomas claimed that the court had interpreted the Pregnancy Discrimination Act in such a manner that a new law was created that was non-existent in the Act. According to the dissenters, “To ‘treat’ pregnant workers ‘the same... as other persons,’ we are told, means refraining from adopting policies that impose ‘significant burden[s]’ upon pregnant women without ‘sufficiently strong’ justifications” (Legal Information Institute). They added: “Where do the ‘significant burden’ and ‘sufficiently strong justification’ requirements come from? Inventiveness posing as scholarship - which gives us an interpretation that is as dubious in principle as it is senseless in practice” (Legal Information Institute).

Commentary
The case of Peggy Young vs. United Parcel Service Inc. (UPS) is a remarkable one, considering that it was complex and finally decided in a manner that shaped the employer-employee relationship.
The Supreme Court’s ruling was important because it helped the cause for human rights. The ruling took note of important legal frameworks and American cases in order to declare the attributes of each party. The Supreme Court’s move of referring to Title IV of the EEOC, the Civil Rights Act, and other statutes proves the legal element of the ruling. In this case, the Supreme Court succeeded in conforming to the principles of public policy. It is in the interest of all Americans that the society avoids discrimination of any form.

Ethical Issues
The Peggy Young vs. United Parcel Service Inc. case contained a number of ethical issues, although these are not covered in the source texts. One of the ethical issues is the failure of the company’s Human Resources department to understand that a pregnant woman could not maneuver loads as heavy as those she managed prior to pregnancy. A pregnant woman is more delicate and at greater risk compared to a person with a natural disability. Any injury incurred may cause harm to both the woman and the unborn child. In addition, Peggy had previously experienced several miscarriages, earning her greater credibility in the case. Another ethical issue relates to Young being denied the medical benefits she had qualified for while still an employee of UPS. The company should have continued to pay medical cover and other similar expenses, since it had not sacked Peggy. Peggy was not away from her job of her own volition, but because of a condition that was clear and visible to everyone.

Conclusion
The Peggy Young vs. United Parcel Service Inc. case concerned disparate discriminatory treatment due to pregnancy. However, it referred the case to the Court of Appeals Fourth Circuit for further interpretation. This court upheld the ruling by the District Court, but referred to the Supreme Court for certain clarifications. The Supreme Court ended up revoking the previous judgments, and decided in favor of Peggy. It then sent the case back to the lower courts for fresh determination. The Peggy Young vs. United Parcel Service Inc. will be useful in the future as a reference point by courts that will encounter problems in interpreting the Pregnancy Discrimination Act and the Civil Rights Act. In the future, the concerns raised by the dissenting part as in the interpretation of the Pregnancy Disability Act will become an issue to affect any intention to refer to this case a case law.