Gender discrimination in the workplace, particularly attitudes about pregnancy and childbirth, has been a persistent issue despite legal efforts to address and rectify such disparate treatment. Such efforts have led to substantial legislation from both states’ legislatures and Congress including the Pregnancy Discrimination Act (PDA) which is discussed in Young v. United Parcel Service, Inc. The United States Supreme Court held in Young that “an individual pregnant worker who seeks to show disparate treatment through indirect evidence may do so through application of the McDonnell Douglas framework.” Under the McDonnell Douglas framework, the plaintiff must show that (1) she is a member of a protected class, (2) she informed her employer of her need to be accommodated, (3) the employer failed to provide accommodation to the plaintiff, and (4) the employer accommodated similarly situated individuals. The employer might then attempt to rebut by citing valid grounds for refusing the request for accommodation. However, the employer may not cite the cost or convenience of providing such accommodations as the reason for denying them.

While both parties in Young disagreed regarding the interpretation of the PDA’s second clause, the Court determined that the Act required employers to accommodate pregnant employees as they would their nonpregnant counterparts who are similar in their ability or inability to work.

This case note aims to conduct a retrospective analysis of Young. It seeks to examine its implications in the context of gender discrimination through the lens of feminist jurisprudence and its impact on workplace policies by employing different feminist legal theories. Specifically, it explores how the decision in Young influenced the understanding and enforcement of gender-related employment rights and how feminist jurisprudence perspectives can contribute to a more nuanced interpretation of the case.