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Kimberlie Michelle Durhamv.Rural/Metro Corporation

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.18-14687
DecidedApril 17, 2020
Reporter575 U.S. 206
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilEmployment LawEmployment DiscriminationTitle VIICivil RightsStatutory InterpretationFirst ImpressionRemandSpecial Concurrence
Case Summary

Kimberlie Durham worked as an emergency medical technician whose job required regular lifting. During pregnancy, her physician restricted her from lifting more than fifty pounds, so she requested temporary light duty or dispatcher work. Rural/Metro had accommodated employees injured on the job with similar or more restrictive lifting limits but generally did not accommodate off-the-job injuries. The Eleventh Circuit held that the district court had applied the Supreme Court’s Young v. United Parcel Service pregnancy-discrimination framework incorrectly at summary judgment. The Pregnancy Discrimination Act does not automatically require the most favorable accommodation given to any other worker, but an employer’s policy choices may support an inference of intentional discrimination. The court remanded for the district court to evaluate the remaining legitimate-reason and pretext questions under that framework. Judge Boggs concurred with additional explanation about the placement of the comparator analysis.

Opinion

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Kimberlie Michelle Durham V. Rural/Metro Corporation — The Atlanta Gleaner