''United Automobile Workers v. Johnson Controls, Inc.'', 499 U.S. 187 (1991), was a decision by the
Supreme Court of the United States
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
establishing that
private sector
The private sector is the part of the economy, sometimes referred to as the citizen sector, which is owned by private groups, usually as a means of establishment for profit or non profit, rather than being owned by the government.
Employment
The ...
policies prohibiting women from knowingly working in potentially hazardous occupations are
discriminatory
Discrimination is the act of making unjustified distinctions between people based on the groups, classes, or other categories to which they belong or are perceived to belong. People may be discriminated on the basis of race, gender, age, relig ...
and in violation of
Title VII
The Civil Rights Act of 1964 () is a landmark civil rights and labor law in the United States that outlaws discrimination based on race, color, religion, sex, and national origin. It prohibits unequal application of voter registration requir ...
and the
Pregnancy Discrimination Act
The Pregnancy Discrimination Act (PDA) of 1978 () is a United States federal statute. It amended Title VII of the Civil Rights Act of 1964 to "prohibit sex discrimination on the basis of pregnancy."
The Act covers discrimination "on the basis of ...
of 1978. 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.
Opinion of the Court
The
majority opinion
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision.
Not all cases have ...
by
Justice Blackmun
Harry Andrew Blackmun (November 12, 1908 – March 4, 1999) was an American lawyer and jurist who served as an Associate Justice of the Supreme Court of the United States from 1970 to 1994. Appointed by Republican President Richard Nixon, Blac ...
held that that Title VII prohibits gender–specific
fetal protection policies. Hence based on that statute, the Court decided against
Johnson Controls
Johnson Controls International is an American
Irish-domiciled multinational conglomerate headquartered in Cork, Ireland, that produces fire, HVAC, and security equipment for buildings. As of mid-2019, it employed 105,000 people in around 2,0 ...
by concluding that the company’s fetal protection policy contravened Title VII of the Civil Rights Act of 1964, as amended by the
PDA
PDA may refer to:
Science and technology
* Patron-driven acquisition, a mechanism for libraries to purchase books
*Personal digital assistant, a mobile device
* Photodiode array, a type of detector
* Polydiacetylenes, a family of conducting poly ...
; 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
In employment law, a ''bona fide'' occupational qualification (BFOQ) (US) or ''bona fide'' occupational requirement (BFOR) (Canada) or genuine occupational qualification (GOQ) (UK) is a quality or an attribute that employers are allowed to consid ...
(BFOQ) defense because the protection of employees' fetuses was not an essential part of the business's operation.
[
][
][
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.[
][
][
Audio files available for the Oral Argument and the Opinion Announcement]
References
Further reading
*
External links
* {{caselaw source
, case = ''United Automobile Workers v. Johnson Controls, Inc.'', {{ussc, 499, 187, 1991, el=no
, googlescholar =https://scholar.google.com/scholar_case?case=16132234154136361578
, justia =https://supreme.justia.com/cases/federal/us/499/187/
, loc =http://cdn.loc.gov/service/ll/usrep/usrep499/usrep499187/usrep499187.pdf
, oyez =https://www.oyez.org/cases/1990/89-1215
United States Supreme Court cases
United States Supreme Court cases of the Rehnquist Court
1991 in United States case law
1991 in Wisconsin
Wisconsin law
Civil rights in the United States
Women's rights in the United States
United States gender discrimination case law
History of the United Auto Workers