United Automobile Workers v. Johnson Controls, Inc.
United Automobile Workers v. Johnson Controls, Inc., 499 U.S. 187 (1991), was a decision by the Supreme Court of the United States establishing that private sector policies prohibiting women from knowingly working in potentially hazardous occupations are discriminatory and in violation of Title VII and the Pregnancy Discrimination Act of 1978.[1] The case revolved around Johnson Controls' policy of excluding fertile women from working in battery manufacturing jobs because batteries contain high amounts of lead, which entails health risks to people's reproductive systems (both men and women) and fetuses. 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]
| 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 no. | 89-1215 |
| Citations | 499 U.S. 187 (more) 111 S. Ct. 1196; 113 L. Ed. 2d 158 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | 680 F. Supp. 309 (E.D. Wis. 1988); affirmed, 886 F.2d 871 (7th Cir. 1989); cert. granted, 494 U.S. 1055 (1990). |
| 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 | |
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. The court rejected Johnson Controls' argument that their policy fell under the Bona Fide Occupational Qualification (BFOQ) defense because the protection of employees' fetuses was not an essential part of the business's operation. [3][4][5][6][7][8]
References
- United Automobile Workers v. Johnson Controls, Inc., 499 U.S. 187 (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. ISBN 9781305156104.
- Schneid, Thomas D. (2012). Discrimination Law Issues for the Safety Professional. Boca Raton, Florida. pp. 168–171. ISBN 9781439867792.
- "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.
External links
- Text of United Automobile Workers v. Johnson Controls, Inc., 499 U.S. 187 (1991) is available from: Google Scholar Justia Library of Congress Oyez (oral argument audio)