California Federal Savings & Loan Association v. Guerra
United States Supreme Court
479 U.S. 272 (1987)
California's FEHA required employers to reinstate employees returning from pregnancy disability leave to the same or a similar position absent business necessity, a protection not required for other forms of disability leave; when Cal Fed (plaintiff) told a returning employee, Garland, that no position was available, she filed a complaint with the state agency (defendant), and Cal Fed separately sued seeking a declaration that federal law (Title VII as amended by the Pregnancy Discrimination Act) preempted the state reinstatement requirement. The Ninth Circuit ruled against Cal Fed, and the Supreme Court granted certiorari.
Whether Title VII, as amended by the Pregnancy Discrimination Act, preempts a state law requiring reinstatement specifically for employees returning from pregnancy disability leave, when no comparable reinstatement requirement applies to other forms of disability leave.