California Federal S. & L. Assn. v. Guerra

California Federal S. & L. Assn. v. Guerra: The Background

The United States Supreme Court Case of California Federal S. & L. Assn. v. Guerra dealt with Title VII of the Civil Rights Act of 1964, which prohibits discrimination on the basis of pregnancy. The case of California Federal S. & L. Assn. v. Guerra was initiated when the petitioner filed a suit claiming that a California statute requiring employers to make an effort to rehire workers after maternity leave treated pregnant workers unfairly to other workers. The petition to initiate California Federal S. & L. Assn. v. Guerra also stated that the statute pre-empted by the federal law.

The case of California Federal S. & L. Assn. v. Guerra deals with the fact that state laws may provide more protections than similar federal laws so long as the local law is not incongruent with the stated goals of the federal law.

The case of California Federal S. & L. Assn. v. Guerra looked at the California Fair Employment and Housing Act which disallowed discrimination in housing and employment matters. The state of California amended this piece of legislation to proscribe certain forms of employment discrimination based on pregnancy. This amendment applied to employers subject to Title VII and required these entities to provide female employees with unpaid pregnancy disability leave for up to four months.

Title VII of the Civil Rights Act of 1964 also outlaws employment discrimination based on sex; however, previous case law determined that discrimination based on pregnancy was not categorized as discrimination based on sex under Title VII.

California Federal S. & L. Assn. v. Guerra: The Question

The primary question of California Federal S. & L. Assn. v. Guerra asked whether or not Title VII of the Civil Rights Act of 1964—as amended by the passing of the Pregnancy Discrimination Act of 1978—pre-empt state laws requiring employers to provide leave and subsequent reinstatement to employees disabled by pregnancies.

California Federal S. & L. Assn. v. Guerra: The Ruling

The case of California Federal S. & L. Assn. v. Guerra held that the California state law is not inconsistent with the purposes of the federal law. As a result of this decision, the United States Supreme Court in California Federal S. & L. Assn. v. Guerra held that the statute is indeed valid.

The dissenting opinion offered in California Federal S. & L. Assn. v. Guerra stated that the second clause of the PDA requires that pregnant employees be treated uniformly therefore leaving no room for preferential treatment of pregnant workers.

The majority in California Federal S. & L. Assn. v. Guerra found that Title VII as amended by the PDA created a requirement that pregnant workers be treated as equal. They found that the state law was an acceptable expansion of a pregnant worker’s rights and it was not incongruent with the purposes of the federal law.