United Automobile Workers v. Johnson Controls, Inc.
| United Automobile Workers v. Johnson Controls, Inc. | |
|---|---|
|
| |
| Argued October 10, 1990 Decided March 21, 1991 | |
| Full case name | International Union, United Automobile, Aerospace & Agricultural Implement Workers Of America, UAW, et al. vs. Johnson Controls, Inc. |
| Docket nos. | 89-1215 |
| Citations | |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Holding | |
| Title VII, as amended by the Pregnancy Discrimination Act of 1978, forbids sex-specific fetal-protection policies, as incapability of becoming pregnant is not a "bona fide occupational qualification." | |
| Court membership | |
| |
| Case opinions | |
| Majority | Blackmun, joined by Marshall, Stevens, O'Connor, Souter |
| Concurrence | White, joined by Rehnquist, Kennedy |
| Concurrence | Scalia |
| Laws applied | |
| Pregnancy Discrimination Act of 1978 | |
United Automobile Workers v. Johnson Controls, Inc. 499 U.S. 187 (1991)[1] is a decision by the Supreme Court of the United States establishing that private sector policies which allow men but not women to knowingly work in potentially hazardous occupations is gender discrimination and violates Title VII of the 1964 Civil Rights Act as amended by the Pregnancy Discrimination Act of 1978. At the time the case was heard, it was considered one of the most important sex-discrimination cases since the passage of Title VII.[2]
Opinion of the Court
The majority opinion by Justice Blackmun held that that Title VII prohibits gender specific fetal protection policies. Hence based on that statute, the Court decided against Johnson Controls by concluding that the company’s fetal protection policy contravened Title VII of the Civil Rights Act of 1964, as amended by the PDA; and the company's gender-specific rule was biased and inequitable because it permitted fertile men, but not fertile women, to decide whether to work in jobs subjected to lead exposure while manufacturing batteries.[3][4][5][6][7][8]
References
- ↑ Workers v. Johnson Controls, Inc., 499 U.S. 187, 111 S. Ct. 1196, 113 L. Ed. 2d 158 (1991)
- ↑ Presser, Arlynn Leiber; Bertin, Joan (June 1990). "Women at Work: Should 'Fetal Protection' Policies Be Upheld". ABA Journal. American Bar Association. 76 (6): 38–39.
- ↑ Mezey, Susan Gluck (2008). "UAW v. Johnson Controls, 499 U.S. 187 (1991)" (Gale: U.S. History in Context). Encyclopedia of the Supreme Court of the United States. Volume 5. Macmillan Reference USA.
- ↑ Shapiro, Robert A. (Associate Solicitor for Legislation and Legal Counsel) (July 11, 1991). "Policy guidance on the Supreme Court Decision". Occupational Safety & Health Administration.
- ↑ Bernstein, Andrew Evan (1992). "UAW v. Johnson Controls: A Final Word on Fetal Protection Policies and Their Effect on Women's Rights in Today's Economy." Hofstra Labor and Employment Law Journal 9.2: 5.
- ↑ Jennings, Marianne (2015). Business: Its Legal, Ethical, and Global Environment. Canada: Cengage Learning. pp. 715–722.
- ↑ Schneid, Thomas D. (2012). Discrimination Law Issues for the Safety Professional. Boca Raton, Florida: CRC Press; Google Books. pp. 168–171.
- ↑ "United Automobile Workers v. Johnson Controls, Inc" (Web page with Audio Files). 0YEZ Project. Chicago-Kent College of Law. 2015. Audio files available for the Oral Argument and the Opinion Announcement
Further reading
- Grover, Susan, Faculty Publications. Paper 179. "The Employer's Fetal Injury Quandary After Johnson Controls" (Free PDF download). Kentucky Law Journal. College of William & Mary Law School. 81: 639.