Nashville Gas Co. v. Satty

Under the seniority policy used by Nashville Gas Company (Nashville Gas) (defendant), an employee who took a leave of absence from work due to illness or a disability other than pregnancy retained job seniority and continued to accumulate seniority while on leave. However, an employee who took a leave of absence for other reasons, including pregnancy, lost any job seniority accumulated prior to the leave. Nashville Gas did not hold pregnant employees’ jobs open while the employees were on leave. Rather, once an employee returned from leave after giving birth, Nashville Gas placed the employee in any open position for which the employee was qualified and for which no current employee was bidding. Although the employee could eventually regain previously accumulated seniority for purposes of pensions and vacations, the employee could no longer use previously accumulated seniority for purposes of bidding on future job openings at the company. Nashville Gas also had a practice of providing sick pay to employees who were disabled for limited periods of time due to nonoccupational sickness or injury, but the company did not provide sick pay to employees who were disabled due to pregnancy. Nora Satty (plaintiff) sued Nashville Gas, alleging that the company’s seniority and sick-pay policies violated Title VII of the Civil Rights Act of 1964 (Title VII). Nashville Gas did not produce any proof of a business necessity justifying its policies, and the district court assumed that there was no such justification. The district court entered judgment in Satty’s favor, and the appellate court affirmed. The United States Supreme Court granted certiorari.