General Electric Co. v. Gilbert, 429 U.S. 125 (1976), is a 1976 United States Supreme Court case authored by Chief Justice William Rehnquist concerning gender-based discrimination under Title VII of the Civil Rights Act of 1964. In a 6–3 decision, the Court held that pregnancy could reasonably be excluded from an employer's the disability benefits plan. The Court's majority opinion applied its conclusion in Geduldig v. Aiello (1974),[1] which held that exclusion of pregnancy from a disability plan did not violate the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. Without a showing that pregnancy-based distinctions are "mere pretexts designed to effect an invidious discrimination", Geduldig required only a reasonable basis for the pregnancy-based distinction.[2]
| General Electric Company v. Gilbert | |
|---|---|
 | |
| Argued January 19–20, 1976 Reargued October 13, 1976 Decided December 7, 1976 | |
| Full case name | General Electric Company v. Martha V. Gilbert, et al. |
| Citations | 429 U.S. 125 (more) |
| Argument | Oral argument |
| Case history | |
| Prior | Relief granted, 375 F.Supp. 367, (E.D.V.A. 1974); decision affirmed, 519 F.2d 661 (4th Cir. 1975); cert granted, 423 U.S. 822 (1975). |
| Holding | |
| Petitioners' disability benefits plan does not violate Title VII because of its failure to cover pregnancy-related disabilities. United States Court of Appeals for the Fourth Circuit reversed. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rehnquist, joined by Burger, Powell, Stewart, White; Blackmun (in part) |
| Concurrence | Stewart |
| Concurrence | Blackmun (in part) |
| Dissent | Brennan, joined by Marshall |
| Dissent | Stevens |
| Laws applied | |
| Title VII of the Civil Rights Act of 1964 | |
Superseded by | |
| Pregnancy Discrimination Act of 1978 | |
The decision in Gilbert generated considerable backlash and prompted Congress to abrogate it by passing the Pregnancy Discrimination Act of 1978.[3][4] The Supreme Court itself later acknowledged that this Act had overturned its holding in Gilbert, namely, that pregnancy discrimination was not unlawful sex discrimination under Title VII.[5]
References
edit- ^ Geduldig v. Aiello, 417 U.S. 484 (1974)
- ^ "The Court of Appeals expressed the view that the decision in Geduldig had actually turned on whether or not a conceded discrimination was 'invidious' but we think that in so doing it misread the quoted language from our opinion. As we noted in that opinion, a distinction which on its face is not sex related might nonetheless violate the Equal Protection Clause if it were in fact a subterfuge to accomplish a forbidden discrimination. But we have here no question of excluding a disease or disability comparable in all other respects to covered diseases or disabilities and yet confined to the members of one race or sex. Pregnancy is, of course, confined to women, but it is in other ways significantly different from the typical covered disease or disability. The District Court found that it is not a 'disease' at all, and is often a voluntarily undertaken and desired condition, 375 F. Supp., at 375, 377." Gilbert 429 US at 136
- ^ Grossman, Joanna (January 1, 2016). "Expanding the Core: Pregnancy Discrimination Law as It Approaches Full Term". Idaho Law Review. 52: 825.
- ^ Liss, Shannon E. (1997). "The Constitutionality of Pregnancy Discrimination: The Lingering Effects of Geduldig and Suggestions for Forcing its Reversal". N.Y.U. Review of Law & Social Change. 23 (1): 59.
- ^ Newport News Shipbuilding Co. v. EEOC, 462 U.S. 669 (1983)
External links
edit- Text of General Electric Co. v. Gilbert, 429 U.S. 125 (1976) is available from: CourtListener Google Scholar Justia Library of Congress Oyez (oral argument audio)
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