AUTOMOBILE WORKERS V. JOHNSON CONTROLS, INC.

AUTOMOBILE WORKERS V. JOHNSON CONTROLS, INC., 499 U.S. 187 (1991), a Supreme Court case that found an employer's fetal protection policy to be invalid under federal antidiscrimination laws. Johnson Controls had established a protection policy excluding fertile women but not men from jobs exposing workers to lead during the manufacture of batteries. Lower federal courts ruled that the employer's concern for protecting the next generation as well as potential liability for birth defects took precedence over equal employment opportunities for women. The Supreme Court, however, held that Title VII of the Civil Rights Act of 1964 and the Pregnancy Discrimination in Employment Act of 1978 prevented this type of employment discrimination against women. Moreover, because males also faced risk to their reproductive capacities from lead exposure, the facts of the case indicated discrimination based solely on gender and childbearing ability.

Johnson Controls failed to prove that its gender discrimination was a legitimate sexually based bona fide occupational qualification for the manufacture of batteries. According to the Court, Congress intended in its legislation to let women and their families, not employers, decide for themselves as to the relative importance of economic and reproductive roles. Considering that tens of millions of industrial jobs could have been denied to women applicants if the lower-court decisions had stood, Automobile Workers v. Johnson Controls was widely regarded as one of the most important sex discrimination cases since 1964 and a landmark in the abortion debate over fetal rights.

BIBLIOGRAPHY

Baer, Judith A. Women in American Law. New York: Holmes and Meier, 1996.

Sullivan, George M., and William A. Nowlin. "Gender-Based Fetal Protection Policies: Impermissible Sex Discrimination." Labor Law Journal 42 (July 1991).

Gilbert J.Gall/a. r.

See alsoAbortion ; Discrimination: Sex ; Pregnancy Discrimination Act .