Michigan
How International Union, UAW v. Johnson Controls, Inc. applies in Michigan: state-specific rules, key cases, and bar exam notes for Employment Discrimination.
Michigan law aligns with the principles set forth in Johnson Controls by prohibiting discrimination based on sex, particularly relating to reproductive status. This is embodied in the Michigan Elliott-Larsen Civil Rights Act, which mirrors the federal stance against discriminatory employer practices.
Employers in Michigan cannot discriminate on the basis of sex, including decisions related to employment based on the reproductive health or capacity of employees, mirroring the protections established in Johnson Controls.
The court reinforced that discrimination based on pregnancy or childbirth constitutes sex discrimination under the Elliott-Larsen Civil Rights Act.
The court held that discriminatory practices impacting employees’ reproductive health are actionable under state law, extending protections analogous to those in Johnson Controls.
The court recognized that discriminating against pregnant employees violates public policy in line with risks outlined in Johnson Controls.
Michigan's approach is similar to the federal standards set by Title VII of the Civil Rights Act, specifically in its applicability to sex discrimination. However, Michigan law may provide broader protections by explicitly addressing reproductive health and capacity, which is not as deeply elaborated in federal law.
The Michigan bar exam may include questions on state interpretations of employment discrimination law, especially regarding cases involving reproductive capacity and the applicability of the Elliott-Larsen Civil Rights Act.