Automobiles Workers v. Johnson Controls, Inc.
499 U.S. 187(1991)
Pingping Wang
Florida International University
BUL6810: The Legal Environment of Business

Abstract

This paper is generally about the case analysis about the supreme court case Automobiles Workers v. Johnson Controls, Inc. based on the legal documents, such as the Civil Rights Acts of 1964, and Pregnancy Discrimination Act of 1987. This case is focus on the primary prospective of the Pregnancy Discrimination between the employers and employees, providing the elaborate and personal comprehension of this case issues, and then describes the inspiration refined from this case.

Contents

1.Introduction 2
2. Case analysis 3 2.1 The procedure of the case receiving 3 2.2The related legal document analysis 5 2.2.1 The Civil Right Act of 1964 (Title VII) 5 2.2.2 The Pregnancy Discrimination Act of 1978 7 2.3 The causation analysis of the supreme court’s decisions based on personal comprehension 8
3. The inspiration of the case 10
4. Conclusion 11
Reference 11

Automobile Workers v. Johnson Controls, Inc,

499U.S.187 (1991)

1.Introduction Presently, the employment relationship is becoming a hot-button topic among the public, protecting the employees’ legitimate interest detailed reform and implementation in the field of the law. This supreme court case is generally about the equal employment relationship between the employers and employees. It happens between the Automobile workers and the Johnson Controls, Inc. Johnson Controls, Inc is an American company offering the products and service to optimize the energy and the operational efficiency of buildings, automotive batteries, etc. However, during the procedure of manufacturing the automotive batteries, the occupational exposure of the primary ingredients, lead, will entail a health risk of the manufacture workers, which especially includes the risk of harm towards any fetus carried by the female employees. Therefore, the respondent of Johnson Controls, Inc announced a policy that barring all women from jobs involving actual or potential lead exposure exceeding the OSHA standard, except for the women whose infertility was medically documented. This so-called fetal-protection policies evinced the petitioners consist of the employees affected by the respondents’ fetal-protection policies and filed the action to the District Court to claim that the policy contain the sex discrimination which violates the title VII of the Civil Rights Act of 1964.
2. Case analysis 2.1 The procedure of the case receiving Afterwards, the District Court granted summary judgment for the respondent, and the Court of Appeal affirmed and held that “the proper standard for evaluating the policy was the business necessity inquiry, and the respondent of Johnson Control still was entitled to summary judgment, the petitioners has failed to satisfy their burden of persuasion in each elements of the business necessity inquiry, and its fetal-protection policy is reasonably necessary to the industrial safety concern. Furthermore, this case has gone through a very long period of arguing and discussed among the courts that affirmed, as followed are some pivotal information during the case receiving. After going through the District Court, the District Court mentioned the disagreement among the experts about the effects on lead to the fetus, and illustrated that the petitioners had failed to establish an acceptable alternative policy which would protect the fetus. Then the court of Appeal review the opinions of the Fourth and the eleventh Circuit, and conclude the three step business necessity defense is given clearly about judging this case, “firstly, whether there is a substantial health risk to the fetus. Secondly, whether transmission of the hazard to the fetus occurs only through women; Thirdly, whether there is a less discriminatory alternative equally capable of preventing the health hazard to the fetus.”(Automobile Workers v. Johnson Control, Inc., 1991) In addition , the Court of Appeals assumed that the fetal-protection policy is facially neutral, for it had only effect on the women’ s employment opportunities, and its purpose is to protect the women’s unconceived offspring, it was ostensibly benign. Therefore, the Court of Appeal ruled that Johnson Controls should prevail and “ there was no genuine issue of material fact about the substantial health-risk factor, because the parties agreed that there was a substantial risk to a fetus from lead exposure”. At the final part of this case, the supreme court made an unanimous decision that even though the “fetal-protection” policies are well intentioned , Johnson Control still need to be regarded unconstitutional if it indeed result in the pregnancy discrimination, and in this case the Johnson Control did not maintain the men into the proof of sterility, even though the lead exposure will has the same influence on the male employees’ health condition. Quoting by the decision of the supreme court, “ The policy is not neutral because it does not apply to male employees in the same way as it applies to females, despite evidence about the debilitating effect of lead exposure on the male reproductive system.”(Automobile Workers v. Johnson Control, Inc., 1991)Although the lead exposure occupational jobs will do some harm to the reproductive health condition of the employees, the women still can be capable of their job as the men. There is also a sentence in the decision of the supreme court, “ The absence of a malevolent motive does not convert a facially discriminatory policy into a neutral policy with a discriminatory effect.” (Automobile Workers v. Johnson Control, Inc., 1991) At the end, the decision of the supreme court symbolized the victory of the women who has been barred from jobs because of the lead exposure hazard. 2.2The related legal document analysis 2.2.1 The Civil Rights Act of 1964 (Title VII) In this case, the primary legal document is the Civil Right Act of 1964, which is focus on the right protection, the anti-discrimination and the legitimate interest protection, and this case is focusing on the Title VII, The Equal Employment Opportunities. In this Title the Civil Right Act of 1964 has given a very elaborated definition of the person, the employees and the employers, the employer agency, and the labor organization , etc. , and clearly regulates the obligations and prohibits of these characters played in people’s daily life. In addition, relating to the pregnancy discrimination, there is a statute that “It shall be an unlawful employment practice for an employer---(2) To limit, segregate, or classify his employees in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of such employee’s race, color, religion, sex, or national origin.”(Civil Rights Act of 1964). During the case receiving it could be found out that there is a discriminatory effect produced by the “ fetal-protection” policy. Johnson Control has not maintained the male employees into the issue, and just or only required the female employees to demonstrate the proof of sterility, even though there will be the same influence towards the reproductive health risk of the male employees who are also engaged in the lead exposure job. Furthermore, the excuse is usually used by the employers about the discrimination on the basis of women’s ability to become pregnancy. In this case, eight of its female employees has become pregnant while maintaining blood lead levels exceeding that noted by the Occupational Safety and Health Administration (OSHA), and the Johnson Control barred the women whose blood lead has exceeded the standard , and the women who got the proof of the sterility could be exempted from the job exclusion. This fetal-protection policy has led to a discriminatory effect towards the female employees, even the pregnant female employees could also has the capability to insisting on the occupation like the men. This situation has created a discriminatory effect towards the women employees. Moreover, there is also a sentence in the Stature 703 (e) “(1)It shall be an unlawful employment practice for a labor organization to exclude or expel from its membership, or otherwise to discriminate against any individual, because of his race, color, religion, sex, or national origin” (Civil Right Act of 1964) In addition, the Johnson Control uses the words “capable of bearing children” as the criteria for getting the employees excludes from the job, therefore, it also violates the rules of the Civil Rights shown above, and how about the case under the Pregnancy Discrimination Act (PDA)?
2.2.2 The Pregnancy Discrimination Act of 1978 The pregnancy Discrimination Act is an Act to amend Title VII of the Civil Rights Act of 1964 to prohibit sex discrimination on the basis of pregnancy. There is an added up statutes that “pregnancy, childbirth or related conditions; and women affected by pregnancy, childbirth, or related medical conditions shall be treated the same for all employment-related purposes, including receipt of benefits under fringe benefit programs, as other persons not so affected but similar in their ability or inability to work ”(The Pregnancy Discrimination, 1978) Therefore, in retrospect of this case, there is a very crucial procedure in this case receiving is that Johnson Controls has shifted from a policy of warning to a policy of exclusion from 1982 to 1985. Besides, Johnson Control has announced that “ the women who are pregnant or who are capable of bearing children will not be placed into jobs involving lead exposure”(Automobile Workers v. Johnson Control, Inc., 1991), and the statement of warning the exposure hazard was signed by the employees, which illustrates that the pregnant female employees have already known the hazard of the exposure, and still has not given up the opportunities of working. However, based on the fetal-protection policies the Johnson Control has directly excluded the occupation of the pregnant women, which has violated the Pregnancy Discrimination Act.
2.3 The causation analysis of the supreme court’s decisions based on personal comprehension Original, the first time I skimmed the case, and when I did not finish the supreme court circuit, I held the opinion that Johnson Control,Inc. would have got the opportunities to prevail the case. I did the further research that Before the Civil Rights Act of 1964 becoming Law, Johnson Control even did not hire any women in manufacturing the battery until 1977 when it made the first policy announcement. Meanwhile, Johnson Control, Inc has already illustrated the emphasis on that a woman who expected to have a child should not choose a job in the battery exposure. Besides, the Johnson Control.Inc also requires the woman who has the desire to work in the battery manufacturing to sign the statements that she would like to bear the risk of not having a baby in the rest of her life. Influenced by the Tort Law I have learned from the former chapters of the course of Legal Environment, it reminds me that the term of “ the restrict liability of the products”, the employers have warned the female employees who wanted to join the jobs, and made an announcement of the reproductive health risk, the Comparative Fault defenses that the plaintiff could use for reducing the Damage and accountability. It also reminds me the Contract Law that the employees have signed a contract with the employers, which means that there is a mutual agreement lying between the employees and the employers. All of these knowledge led me to the side of the Johnson Control, Inc. However, there is a turning point after finishing all the court procedure of this case. Under the Pregnancy Discrimination Act (PDA), most of the pregnancy discrimination will be involved in a disparate treatment, which includes the “intentional discrimination, and a facial neutral policy or practice that impacts one group more harshly than the another in a manner that can not be justified by business necessity.” (Alexanda.K.H, 1998) There are some obvious evidence and key points to admit the pregnancy discrimination of Johnson Control,Inc. First and Foremost is the “fetal-protection” policies. It is facially neutral for the asserted purpose the respondents of Johnson Control, Inc., has announced that in order to protect the women from unconceived offspring, and offer the protection of the fetus carried by the female employees, that sounds really benign. However, actually, it is not a neutral policy, there are another group of the people being ignored by this policy, it is the male employees. This policy does not apply the male workers into the range of the management, even though the lead exposure will has the same influence on the reproductive health risk on the male employees. Furthermore, for the common sense, delivering the babies still needs the father to build up a family. Therefore, in this manner, the Johnson Control, Inc has been related to the issue of sex and pregnancy discrimination. The second reason is based on the three-step business necessity defense provided by the Court of Appeals. The business necessity defense is related to the employer’s defense and which is consistent with the decision making of the employers. (Alexanda.K.H, 1998) In this case, it should be focus on the following three steps, “whether there is a substantial health-risk to the fetus, together with whether transmission of the hazard to the fetus occurs only through women, and whether there is a less discriminatory alternative equally capable of preventing the health hazard to the fetus.” (Automobile Workers v. Johnson Control, Inc., 1991) All the proof of anything followed by these three steps is advantageous towards the Johnson Control, Inc.
The inspiration of the case After studying this case, I have got a brand new knowledge about the employment relationship, sometimes there are so much tricky relationship between the employers and employees. Signing the labor contract, and know everything about the contract is very important for the employees to protect their legitimate interest in the workplace. There is already an unequivalent relationship existing between the employers and employees for a long time, the employers has mastered more information than the employees, therefore, to protecting the employees from being passive in the company activities, the legal document is very useful and beneficial. However, as for the employers, to assure the employees to keep the loyalty towards the corporation, first of all, is to consider for the employees, not only the profits and revenues of the corporation, to give more inspired activities and appropriately solve the problem in stead of directly barred the workers from jobs. Furthermore, the tiny decision of the employers may influence the whole life of the employees.
4. Conclusion This case generally exhibits the rules of Civil Rights Act of 1964, especially the Title VII to achieve a balance between the employers and employees, preventing from the discrimination and the lower job satisfaction, and the Amended Pregnancy Discrimination Act, which offers a shield for the employees to protect their own legitimate interest, and gives the anti-discrimination movement the legal and document support. The women who have been excluded from jobs by the Johnson Controls, Inc. have got a victory to achieve this prevailing, and It is very important for the employees to get to know which the legal document is protecting their rights and benefits, and which is the general content of the law documents, meanwhile to sign the labor contract more carefully and elaborately, make sure each item describes on the contract, because it will become the evidence to make the defense of the court. Reference
Alexandra K. H, Pregnancy discrimination - rights, remedies, and defenses, 1998, Retrieved from http://go.galegroup.com.ezproxy.fiu.edu/
Alison Shay, Remembering Automobile Workers v. Johnson Controls, Inc. 2012 Retrieve from https://lcrm.lib.unc.edu/blog/index.php/2012/03/20/remembering-automobile-wor kers-v-johnson-controls-inc/
Civil Rights Act of 1964, Title VII, Sec. 703 (a)
Civil Rights Act of 1964, Title VII, Sec. 703 (e)
Preventing Discrimination with Business necessity Retrieved from http://business.laws.com/defenses/business-necessity
The Pregnancy Discrimination Act,1978, Sec. 2&3
The Automobile Workers v. Johnson Controls, Inc,499 U.S.187(1991) Retrieve from http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=499&invol=187
The definition of Johnson Control retrieved from: http://www.johnsoncontrols.com/

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