Shaw v. Delta Air Lines
United States Supreme Court
463 U.S. 85 (1983)
- Written by Alexander Hager-DeMyer, JD
Facts
The State of New York enacted the Human Rights Law and the Disability Benefits Law, both of which prohibited employee benefit plans from treating pregnancy differently from other nonoccupational disabilities or injuries. Under the laws, employers and plan administrators in the state were required to include pregnancy benefits in any employee benefit plan of general coverage. Delta Air Lines, Inc. and other airlines, Burroughs Corporation, and Metropolitan Life Insurance Company (plaintiffs) provided their employees with medical and disability benefits through welfare plans governed by the Employee Retirement Income Security Act (ERISA). These companies filed suit in federal district court against the commissioner of the New York State Division of Human Rights and other government officials (defendants), alleging that the Human Rights Law and Disability Benefits Law were both preempted by ERISA. The district court found that the Human Rights Law was preempted but that the Disability Benefits Law was exempted. The case was appealed to the United States Court of Appeals for the Second Circuit, which affirmed as to the Human Rights Law and remanded the case as to the Disability Rights Law. The case was appealed to the United States Supreme Court, which granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Blackmun, J.)
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