sole cause

California has administered a disability insurance system for almost 30 years. It pays benefits to persons in private employment who are temporarily unable to work because of disability not covered by workers' compensation. The system is funded entirely from contributions deducted from the wages of participating employees. The rate is one percent of salary up to an annual maximum of $85. Those contributions are placed in the Unemployment Compensation Disability Fund. The fund is established as a special trust fund within the state treasury. An individual becomes eligible for benefits after contributing one percent of a minimum income of $300 during a one-year base period. The individual can then receive a weekly benefit amount between $25 and $105 for up to 26 weeks. Additional hospital benefits of $12 per day are available. There is an eight-day waiting period unless the employee is hospitalized. Section 2626 of the California Unemployment Insurance Code defines disability to include mental or physical illness and injury. It expressly excludes from coverage any injury or illness caused by or arising in connection with pregnancy up to the termination of such pregnancy and for a period of 28 days thereafter. Appellant Geduldig, as Director of the California Department of Human Resources Development, administers the program. He applies the exclusion to bar payment of benefits for any disability resulting from pregnancy. Appellees Carolyn Aiello, Augustina Armendariz, Elizabeth Johnson, and Jacqueline Jaramillo each paid sufficient amounts into the Disability Fund to be eligible for benefits. Aiello, Armendariz, and Johnson suffered employment disabilities attributable to abnormal complications encountered during their pregnancies. Jaramillo experienced a normal pregnancy that was the sole cause of her disability. All four were ruled ineligible for benefits under the pregnancy exclusion and sued to enjoin its enforcement. The appellees' consolidated actions were heard by a three-judge federal district court. The court granted summary judgment holding that the exclusion violates the Equal Protection Clause and enjoined its continued enforcement. Shortly before that decision, the California Court of Appeal in Rentzer v. Unemployment Insurance Appeals Board construed section 2626 to preclude benefits only for disability accompanying normal pregnancy. The appellant then issued administrative guidelines excluding only maternity benefits for normal delivery and recuperation and paid the claims of Aiello, Armendariz, and Johnson. Only appellee Jaramillo continues to have a live controversy. Her disability stemmed solely from normal pregnancy and childbirth. The District Court denied the appellant's motion for reconsideration in light of Rentzer. The appellant appealed. The Supreme Court noted probable jurisdiction after granting a stay of the district court's judgment.

In August 1973 Clara Watson, who is black, was hired by Fort Worth Bank and Trust as a proof operator. In January 1976 she was promoted to teller in the Bank's drive-in facility. Between February 1980 and February 1981 Watson applied without success for four supervisory positions, each time losing out to a white applicant. The Bank employed roughly eighty people and had developed no precise formal criteria for the positions. It instead left promotion decisions to the subjective judgment of white supervisors who knew the candidates and the jobs. Watson filed a charge with the Equal Employment Opportunity Commission. After exhausting administrative remedies she sued the Bank in the United States District Court for the Northern District of Texas, alleging racial discrimination in hiring, compensation, placement, promotions, terminations, and other terms of employment. On her Rule 23 motion, the District Court certified a broad class of black applicants and employees, but later decertified it after finding no common question of law or fact. The employee subclass failed the numerosity requirement while Watson was not an adequate representative for applicants. The District Court then addressed Watson's individual promotion claims under the McDonnell Douglas and Burdine framework. It found that she had made out a prima facie case, but the Bank had articulated legitimate nondiscriminatory reasons for each decision. Watson had not proved those reasons pretextual. The court therefore dismissed the action. A divided Fifth Circuit panel affirmed the dismissal of Watson's claims and the class rulings, though it vacated the judgment as to the applicant class and remanded with instructions to dismiss those claims without prejudice. Watson contended that the District Court should have applied disparate impact analysis to the Bank's discretionary promotion practices. The Fifth Circuit held that Title VII challenges to discretionary promotion systems must be analyzed under the disparate treatment model. The Supreme Court granted certiorari to resolve the conflict among the circuits on that question.

Diana Levine, a professional musician, was treated for a migraine headache at a Vermont clinic on April 7, 2000. She received an intramuscular injection of Demerol and Phenergan that provided no relief, so she returned later that day and received a second injection of both drugs administered by the IV-push method. The injection entered an artery, either because the needle penetrated an artery directly or because of perivascular extravasation, and Levine developed gangrene that required amputation of her right hand and then her entire forearm. Levine settled claims against the health center and clinician before bringing a product liability action against Wyeth in Vermont state court. She alleged that Phenergan's labeling was defective because it failed to instruct clinicians to use the IV-drip method of intravenous administration instead of the higher-risk IV-push method. After a five-day jury trial, the jury found Wyeth negligent and that Phenergan was a defective product as a result of inadequate warnings and instructions, awarding total damages of $7,400,000 that the court reduced to account for the prior settlement. Wyeth manufactures Phenergan, an antihistamine used to treat nausea that the FDA first approved in 1955. The injectable form can be administered intramuscularly or intravenously, either by the IV-push method of injecting the drug directly into a vein or by the IV-drip method of introducing it into a saline solution in a hanging intravenous bag. The drug is corrosive and causes irreversible gangrene if it enters a patient's artery. The FDA-approved labeling warned of the danger of gangrene and amputation following inadvertent intra-arterial injection but did not contain a specific warning about the risks of IV-push administration. The trial record contained correspondence between Wyeth and the FDA about Phenergan's label spanning from the 1955 approval through a 1981 supplemental application that the FDA finally approved in 1998. In 1987 the FDA suggested different warnings about the risk of arterial exposure, and Wyeth submitted revised labeling in 1988, but the FDA did not respond and in 1996 instructed Wyeth to retain the verbiage in the current label regarding intra-arterial injection. The record also showed at least twenty incidents prior to Levine's injury in which a Phenergan injection resulted in gangrene and amputation. The trial court denied Wyeth's motion for summary judgment asserting federal preemption. The Vermont Supreme Court affirmed the jury verdict. The Supreme Court of the United States granted certiorari to decide whether the FDA's approvals of Wyeth's drug label precluded Levine from bringing her claim.

Helen Palsgraf purchased a ticket from the Long Island Railroad Company and stood on the platform of its station awaiting a train bound for Rockaway Beach. A train stopped at the station, though it was destined for a different location. Two men hurried to board the moving train. One man successfully reached the platform of the car. The second man, who carried a package approximately fifteen inches long wrapped in newspaper, jumped aboard but appeared unsteady and at risk of falling. A guard on the car held the door open and reached forward to assist the second man, while another guard on the platform pushed him from behind. During this assistance, the package was dislodged and fell onto the railroad tracks. The package contained fireworks, although its appearance gave no indication of these contents. When the package fell, the fireworks exploded, and the resulting shock caused scales located at the opposite end of the platform to topple over. The falling scales struck Helen Palsgraf, resulting in her injuries. She subsequently initiated a lawsuit against the Long Island Railroad Company seeking damages for those injuries. The case proceeded to trial, where a judgment was entered in her favor. The Appellate Division affirmed that judgment, after which the matter came before the Court of Appeals for review.