575 U.S. 206 (2015)
Young v. United Parcel Service, Inc.
Under the Pregnancy Discrimination Act, may a pregnant worker establish a disparate treatment claim when her employer denies her an accommodation that it provides to nonpregnant employees who are similar in their ability or inability to work, and what evidentiary framework governs that claim?
Pregnancy discrimination claims under Title VII's Pregnancy Discrimination Act proceed under the McDonnell Douglas burden-shifting framework, adapted to the PDA's text. A plaintiff makes a prima facie case by showing: (1) she is pregnant (a protected class), (2) she sought an accommodation, (3) the employer denied the accommodation, and (4) the employer did accommodate others who are similar in their ability or inability to work. The employer must then articulate a legitimate, nondiscriminatory reason for denying the accommodation to the plaintiff. Reasons consisting merely of cost or convenience are insufficient. The plaintiff may show pretext by providing evidence that the employer's policies impose a significant burden on pregnant workers and that the employer's reasons are not sufficiently strong to justify that burden. Evidence that an employer accommodates a large percentage of nonpregnant workers while failing to accommodate a large percentage of pregnant workers with similar work limitations can permit a reasonable jury to infer intentional discrimination.
Yes. A pregnant employee can establish a prima facie case of disparate treatment under the PDA by showing she was denied an accommodation given to others similar in their ability or inability to work. Neutral policies do not automatically defeat such claims, and cost or convenience alone is not a sufficient justification. The Court vacated the Fourth Circuit's judgment and remanded for further proceedings under the proper standard.
Young is pivotal for pregnancy discrimination law because it clarifies how courts assess comparators and pretext in PDA disparate treatment cases. It embeds pregnancy-discrimination claims within the familiar McDonnell Douglas framework while articulating a distinctive "significant burden" inquiry tailored to the PDA's equal-treatment command. Practically, it prevents employers from using facial neutrality or convenience-based rationales to defeat claims at summary judgment when their accommodation schemes favor large classes of nonpregnant workers with similar limitations. For students, Young is a study in statutory interpretation (text, history, and purpose), the calibration of burden-shifting frameworks, and the limits of categorical employer policies. It also provides a foundation for understanding later legislative developments, including the federal Pregnant Workers Fairness Act (effective 2023), which imposes an affirmative reasonable accommodation duty distinct from Title VII's disparate treatment paradigm. Post-Young, PDA claims still require comparator and pretext analysis; PWFA claims proceed under an ADA-like undue hardship standard.