Tuesday, March 5, 2013

California Federal Savings & Loan Association v. Guerra case brief

California Federal Savings & Loan Association v. Guerra case brief summary
479 U.S. 272 (1987)

SYNOPSIS: The Court issued a writ of certiorari to the United States Court of Appeals for the Ninth Circuit to determine whether Title VII of the Civil Rights Act of 1964, as amended by the Pregnancy Discrimination Act of 1978, pre-empted a state statute that required employers to provide leave and reinstatement to employees disabled by pregnancy.

FACTS: Cal. Gov't. Code § 12945(b)(2) required that employers reinstate women after a reasonable pregnancy disability leave, and plaintiff employers and organizations challenged its application, claiming that Title VII of the Civil Rights Act of 1964, as amended by the Pregnancy Discrimination Act of 1978, pre-empted the state statute.

HOLDING:
In affirming the judgment that the state statute was not pre-empted, the Court held that it did not compel employers to treat pregnant workers better than other disabled workers, but merely established minimum benefits to be provided to pregnant workers.

ANALYSIS:
The statute was not inconsistent with the purposes of the federal statute, nor did it require the doing of an act that was unlawful under Title VII.

OUTCOME: The judgment of the appellate court was affirmed because in enacting the PDA Congress did not intend to prohibit all favorable treatment of pregnancy.

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