California Federal Savings and Loan Association v. Guerra facts for kids
Quick facts for kids California Federal S. & L. Assn. v. Guerra |
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| Argued October 8, 1986 Decided January 13, 1987 |
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| Full case name | California Federal Savings & Loan Association et al. v. Guerra, Director, Department of Fair Employment and Housing, et al. |
| Citations | 479 U.S. 272 (more)
107 S. Ct. 683; 93 L. Ed. 2d 613
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| Prior history | 758 F.2d 390 (9th Cir. 1985) |
| Holding | |
| § 12945(b)(2) is not preempted by Title VII, as amended by the Pregnancy Discrimination Act, because it is not inconsistent with the purposes of Title VII, nor does it require the doing of an act that is unlawful under Title VII. | |
| Court membership | |
| Case opinions | |
| Majority | Marshall, joined by Brennan, Blackmun, Stevens, O'Connor (Parts I, II, III-B, III-C, IV) |
| Concurrence | Stevens |
| Concurrence | Scalia |
| Dissent | White, joined by Rehnquist, Powell |
| Laws applied | |
| Cal. Gov't Code § 12945(b)(2), Title VII of Civil Rights Act of 1964, Pregnancy Discrimination Act of 1978 | |
California Federal S. & L. Assn. v. Guerra was an important case decided by the U.S. Supreme Court in 1987. This case was about whether a state could require employers to give more benefits for pregnancy than federal law did. It also looked at whether states could require pregnancy benefits for women without giving similar benefits to men. The Court decided that California's law, which required employers to give time off and a job back to employees who were temporarily unable to work due to pregnancy, was okay. It did not go against federal law.
Understanding the Case: Pregnancy Leave and Your Job
This case explores how state laws and federal laws work together. Specifically, it focuses on laws that protect pregnant workers. It's important to know your rights if you or someone you know might need time off for pregnancy.
What Happened? The Story of Lillian Garland
In 1978, California passed a new rule. This rule said that employers had to give a reasonable amount of time off for employees who couldn't work because of pregnancy. Also, these employees had to get their jobs back when they returned.
A woman named Lillian Garland worked for California Federal Savings and Loan. She had worked there for about four years. When she needed to take time off to have her baby, she trained another person to do her job. When she was ready to come back to work, she was told that the person she trained had been given her job permanently.
Lillian Garland felt this was unfair. She believed it went against a federal law called the Pregnancy Discrimination Act of 1978. This federal law made it illegal to treat someone unfairly at work because they were pregnant.
California Federal Savings and Loan argued that California's state law was actually unfair. They said it made them treat pregnant employees differently, which they thought went against the federal law.
The Court's Decision: State vs. Federal Law
The main question for the Supreme Court was whether the California state law was "preempted" by federal law. "Preempted" means that a federal law is so strong or complete that it overrides or cancels out a state law on the same topic.
Justice Marshall wrote the main opinion for the Court. He explained that Congress, which makes federal laws, often says when a federal law should override state laws. Sometimes, federal law is so detailed that it leaves no room for state laws.
However, in this case, Congress had actually said that state laws about employment discrimination could still exist. They would only be overridden if they directly conflicted with federal law. A conflict would happen if:
- It was impossible to follow both the state and federal laws at the same time.
- The state law got in the way of what Congress wanted to achieve with the federal law.
The Court decided that the California law did not conflict with the federal Pregnancy Discrimination Act. In fact, the federal law was meant to set a minimum standard. It said employers could not discriminate against pregnant workers. The California law simply offered more protection. It required employers to give time off, which helped pregnant workers. This extra protection did not make it harder to follow the federal law. Instead, it helped achieve the goal of preventing discrimination and supporting pregnant employees.
Therefore, the Supreme Court ruled that the California law was allowed to stand. It was not "preempted" by federal law. This meant states could offer more benefits to pregnant workers than federal law required.
Justice Scalia wrote a separate opinion agreeing with the outcome. Justices White, Rehnquist, and Powell disagreed with the majority decision.
