Facts of the Case

Provided by Oyez

General Electric Co. offered its employees a disability plan for non-occupational sicknesses and accidents, but the plan did not cover disabilities from pregnancy. The respondents, a class of female employees of General Electric Company, sued their employer for sex discrimination in violation of Title VII of the Civil Rights Act of 1964. The district court held that the plan violated the Act, and the Court of Appeals for the Fourth Circuit affirmed.

Questions

  1. Does the exclusion of pregnancy-related benefits from the company disability plan violate Title VII of the Civil Rights Act of 1964?

Conclusions

  1. No. Justice William H. Rehnquist delivered the opinion of the 6-3 majority. The Court held that employers have the right to exclude any condition from a disability plan with a reasonable basis. The Court referred to a previous decision, Geduldig v. Aniello, which dealt with a similar case under the Equal Protection Clause. In that case, the Court held that the pregnancy exclusion divided the employees into two groups, one that was solely female and the other that contained both sexes, so the distinction is not primarily sex-based. The Court applied the same analysis to this case. Because the disability plan was not worth more to men than it was to women, it did not discriminate based on sex.

    In his concurring opinion, Justice Potter Stewart wrote that this particular case had no impact on the general evidence necessary to prove a discrimination case under Title VII.

    Justice Harry A. Blackmun wrote an opinion concurring in part where he argued that he agreed with the majority’s opinion on the merits of this case but did not agree in any inference that this case would affect overall Title VII decisions.

    Justice William J. Brennan, Jr. wrote a dissenting opinion where he argued that the majority examined the policy in isolation, when it should have considered the policy in light of General Electric Co.’s history of downgrading the role of women in the workforce. Under that framework, the policy was clearly not gender-neutral. He also argued that the political background for this issue indicated that pregnancy exclusions in disability pay drastically affected women’s abilities to remain in the workforce. Justice Thurgood Marshall joined in the dissent.

    In his dissent, Justice John Paul Stevens argued that the Geduldig case should not be the basis for this decision, because the Equal Protection Clause did not contain the word “discrimination.” He found that the language of Title VII required a different analysis than the one the majority used.