United Automobile Workers v. Johnson Controls, Inc.
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''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 tribunals in the United States, federal court cases, and over Stat ...
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, rel ...
and in violation of Title VII 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 hav ...
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
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; 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 consi ...
(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

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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