Confusing Clarity: The Pregnancy Discrimination Act After \u3cem\u3eYoung v. UPS, Inc.\u3c/em\u3e

On March 25, 2015, the Supreme Court issued an opinion in Young v. UPS, Inc.—the most recent case in the Court’s pregnancy discrimination jurisprudence. Young focused on an interpretation of one clause of the Pregnancy Discrimination Act (PDA) and how that interpretation would shape claims of employment discrimination by pregnant employees seeking work accommodations. This Comment argues that the majority opinion in Young did not clarify, but only muddied the waters: the Young framework presents challenges for the lower courts tasked with applying the framework and creates uncertainty for future pregnancy discrimination litigation. Part I of this Comment provides background on the PDA and describes the Court’s approach to pregnancy discrimination prior to Young. Part II summarizes the facts and procedural history of the case, and Part III explains the majority opinion by Justice Breyer. Part IV analyzes three main weaknesses in the majority’s argument: (i) the uncertainty and problems resulting from the Court’s new framework, (ii) the uncertainty surrounding how to handle Equal Employment Opportunity Commission (EEOC) guidelines, and (iii) the confusion that will result from the Court’s failure to address new statutory changes. Part IV then concedes the major strengths of the Court’s argument: (i) consistency with respect to “most-favored-nation” status for employee accommodations, and (ii) the Court’s clear application of rules of statutory interpretation