Institutions, constitutions, actor strategies, and ideas: Explaining variation in paid parental leave policies in Canada and the United States

International Journal of Constitutional Law

Volumn 4, Issue 2, 2006, Pages 319-346

  White, Linda A ^a  

^a UNIVERSITY OF TORONTO   (Canada)

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EID: 33745968231     PISSN: 14742640     EISSN: 14742659     Source Type: Journal    
DOI: 10.1093/icon/mol007     Document Type: Article

References (178)

1. e.g., Kent Greenawalt, Fighting Words (Princeton Univ. Press 1995)
2. Raymond Tatalovich, The Politics of Abortion in the United States and Canada (M.E. Sharpe 1997)
3. Melissa Haussman, Abortion Politics in North America (Lynne Rienner 2005).
4. The Unemployment Insurance Act, 1971, permitted women who had completed 20 weeks of work in the preceding 52 weeks to claim 15 weeks of paid benefits at the same rate as other Unemployment Insurance recipients. Unemployment Insurance Act, S.C. 1971, ch. 48, §st 16(1)(d) and 30, repealed by S.C. 1996, ch. 23, §155.
5. For example, while the Canadian federal government established a limited old age pension scheme in 1927, it did not establish a universal old age security program until 1951, more than fifteen years after the United States implemented its old age security program in 1935. U.S. Social Security Administration, Social Security Programs Throughout the World 56, 135 (U.S. Gov't Printing Office 2003). The U.S. government established a national social assistance program, Aid to Dependent Children (later Aid to Families with Dependent Children) in 1935
6. the Canadian federal government did not follow with a national social assistance program, the Canada Assistance Plan, until 1966, one year after President Johnson launched the American War on Poverty. Human Resources Development Canada, Improving Social Security in Canada. Child Care and Development: A Supplementary Paper 3 (Minister of Human Res. Dev. 1994). More recently, a number of provincial governments in Canada, including Ontario, New Brunswick, and Alberta, adopted "workfare-like" social assistance programs, following U.S. experiments.
7. Leah Vosko, Mandatory 'Marriage' or Obligatory Waged Work: Social Assistance and Single Mothers in Wisconsin and Ontario, in Women's Work is Never Done 165 (Sylvia Bashevkin ed., Routledge 2002). One major exception to this U.S. policy leadership is in the area of health care. In 1957 the Canadian Parliament passed the Hospital Insurance and Diagnostic Services Act, S.C. 1957, ch. 28, in which the federal government offered to share the costs with the provinces of free acute hospital care and lab and radiology services for all Canadians, eight years prior to the establishment of the U.S. Medicare and Medicaid programs in 1965. The Canadian Parliament subsequently passed the Medical Care Act, S.C. 1966, ch. 64, in which the federal government offered to share the costs with the provinces of free access to physician services for all Canadians.
8. See, for example, Joyce Gelb, Feminism and Politics: A Comparative Perspective (Univ. of Cal. Press 1989) on the strength of the U.S. women's movement; for an explicit comparison of the U.S. and Canadian women's movements and their organizational successes,
9. see Lisa Young, Feminists and Party Politics (Univ. B. C. Press 2000).
10. Unemployment Insurance Act, supra note 2.
11. The federal government renamed the program as part of a number of amendments to the program, with passage of the Employment Insurance Act, S.C. 1996, ch. 23.
12. Philip Girard, Why Canada Has No Family Policy: Lessons from France and Italy, 32 Osgoode Hall L.J. 579, 608 (1994).
13. Under the 2002 Employment Act, the U.K. Parliament extended paid maternity leave benefits from eighteen to twenty-six weeks, with a further entitlement to twenty-six weeks unpaid leave, and with increased benefits as well. Employment Act, 2002, c. 22, §18. The act also entitled fathers to two weeks of paid parental leave (§1). For more information see Uk Dept. of Trade and Industry, Employment Relations, available at www.dti.gov.uk/er/employ/.
14. The Workplace Relations Act 1996, amended by Act No. 153 of 2005, permits this leave for permanent full- and part-time employees who have been with their employer for twelve continuous months, Workplace Relations Act, 1996, pt. VIA, div. 5, §170KA.
15. Parental Leave and Employment Protection (Paid Parental Leave) Amendment Act, 2002, No. 7, §4; Parental Leave and Employment Protection Amendment Act, 2004, No. 89, §32. See also Equal Employment Opportunity (EEO) Trust (New Zealand), Work and Life Special Bulletin Details the Paid Parental Leave Scheme Announced November 2001, available at www.womenz.org.nz/pol%20alerts/PPLdetails.htm and the Dep't Labour (New Zealand), Parental Leave General Information, available at www.ers.dol.govt.nz/parentalleave/general.html.
16. Supra note 3.
17. Unemployment Insurance Act, 1971, supra note 2 (Bill C-229).
18. For example, while the Canadian federal government established a limited old age pension scheme in 1927, it did not establish a universal old age security program until 1951, more than fifteen years after the United States implemented its old age security program in 1935. U.S. Social Security Administration, Social Security Programs Throughout the World 56, 135 (U.S. Gov't Printing Office 2003). The U.S. government established a national social assistance program, Aid to Dependent Children (later Aid to Families with Dependent Children) in 1935; U.S. Social Security Administration, supra note 3, various years.
19. Id.; Bill C-16, enacted in 1975, removed that stipulation.
20. See also Ann Porter, Gendered States 124 & 129 (Univ. Toronto Press 2003).
21. See Employment Insurance Act, 1996, supra note 6, at §5 (eligible employees) and § 6(1) and 7(2) (qualification requirements).
22. Katherine Marshall, Benefiting from Extended Parental Leave, in Perspectives, Statistics Canada Cat. No. 75-001-XIE 5, 11 (2003) reports that approximately 39 percent of mothers with newborns in 2001 did not have access to parental leave benefits, either because they were self-employed, were not previously employed, had not worked enough hours to qualify for benefits, or did not apply for them.
23. Melissa Cooke-Reynolds & Nancy Zukewich, The Feminization of Work, in Canadian Social Trends, Statistics Canada Catalogue no. 11-008 72, 24 (2004)
24. Women's Network PEI, Looking Beyond the Surface: An In-depth Review of Parental Benefits, Equity Issues Summary (December 2002).
25. Schachter v. Canada (Employment and Immigration Commission), [1992] 2 S.C.R. 679, where Shalom Schachter wished to obtain parental benefits under the Unemployment Insurance Act, 1971 to allow him to stay home with his child. The government denied his application because neither the maternity benefits provision of the act (section 30) nor the provision for adoptive parents' benefits (section 32) applied to his case. Both the lower court and the Supreme Court found that section 32 of the act violated the section 15 equality provisions of the Canadian Charter of Rights and Freedoms in that it discriminated between "natural" and adoptive parents with respect to parental leave.
26. Bill C-21, An Act to Amend the Unemployment Insurance Act, S.C. 1990, ch. 40, §st 9, 14.
27. Bill C-32, enacted by the Budget Implementation Act, S.C. 2000, ch. 14, §st 2, 3(2).
28. Lesiuk v. Canada (Employment Insurance Commission), [2001] C.U.B.D. No. 1, where an Unemployment Insurance umpire ruled that the requirement that anyone who wishes access to the benefits has to work at least 700 hours (600 hours since January 2001) to qualify is constitutionally unfair to women because, as primary caregivers, often working part-time, it is harder for women than for men to work the hours they need to qualify for the benefits.
29. But see Canada (Attorney General) v. Lesiuk (C.A.), [2003] 2 F.C. 697, where the Federal Court of Appeal overturned the umpire's decision, and the Supreme Court ruling on July 17, 2003 refusing to hear Lesiuk's appeal, S.C.C. 29642.
30. See Employment Insurance Act, 1996, supra note 6, at 2§5(5)(b)
31. Dominique Perusse, New Maternity and Parental Benefits, in Perspectives, Statistics Canada Cat. No. 75-001-XIE 1 (March 2003).
32. Nitya Iyer, Some Mothers are Better Than Others: A Re-examination of Maternity Benefits, in Challenging The Public/Private Divide: Feminism, Law, and Public Policy 168 (S.B. Boyd ed., Univ. Toronto Press 1997)
33. Canada, House of Commons, Parliamentary Standing Committee on the Status of Women, Interim Report on the Maternity and Parental Benefits Under Employment Insurance: The Exclusion of Self-Employed Workers (Communication Canada November 2005).
34. Anne Marie Owen & Heather Sokoloff, Living Large on Maternity Leave, The National Post, Mar. 13, 2004, at RB1, RB5.
35. Canadian Association of Administrators of Labour Legislation (CAALL), Work-Life Balance in
36. Canada: A Report to Ministers Responsible for Labour in Canada 7-8 (2002).
37. Family and Medical Leave Act, 29 U.S.C. §2601, 2612 (1993).
38. Id. at §st 2611(4), 2611(2)(A).
39. Id. at §2614(b).
40. Steven K. Wisensale, Family Leave Policy 6-7 (M.E. Sharpe 2001).
41. Arielle Horman Grill, The Myth of Unpaid Family Leave: Can the United States Implement a Paid Leave Policy Based on the Swedish Model?, 17 Comp. Lab. L.J. 373, 376 (1996).
42. Jane Waldfogel, The Impact of the Family and Medical Leave Act, 18 J. Pol'y Analysis & Mgmt. 281 (1999).
43. U.S. Census Bureau, Statistical Abstract of the United States, tbl. 597 (U.S. Dep't Commerce 2003) reports that the rates for married women with children under age 6 have increased from approximately 30 percent in 1970 to 61 percent in 2002; for single, never-married mothers with children under age 6 from 44 percent in 1970 to 71 percent for 2002; and for widowed, divorced, or separated mothers, from 52 percent in 1970 to 78 percent in 2002.
44. U.S. Census Bureau, Maternity Leave and Employment: Patterns of First-Time Mothers: 1961-2000, tbl. 8 (U.S. Dep't Commerce 2005).
45. Marshall, supra note 15, at 6. She reports, however, that a recent study of the impact of the extension of EI maternity and parental leave benefits found a negligible decline in the percentage of women who returned or planned to return to work within two years after the birth of their child, from 84 to 82 percent. In other words, Canadian women may take long leaves, but they do eventually return to work.
46. Institute for Women's Policy Research (IWPR), The Widening Gap: A New Book on the Struggle to Balance Work and Caregiving, Research-in-Brief 3-4 (2001), emphasis in original.
47. Legal Momentum, Family Initiative: Better Child Care, Preschool and After School: Action Kit 2004 9 (2004).
48. Personal interview, Apr. 21, 2004, Washington, D.C. (transcript on file with author).
49. U.S. Census Bureau, supra note 31, at tbl. 744.
50. U.S. Dep't Lab., Bureau of Lab. Stats., National Compensation Survey-Benefits, available at www.bls.gov/ncs/ebs.
51. See also Michael A. Miller, Time-off Benefits in Small Establishments, Monthly Lab. Rev. 3 (1992).
52. Pinka Chatterji & Sara Markowitz, Does the Length of Maternity Leave Affect Maternal Health?, Working Paper No. 10206 (NBER 2004), available at www.nber.org/papers/w10206.
53. See, e.g., Edward Zigler, Matia Finn-Stevenson & Nancy W. Hall, The First Three Years and Beyond 54-57 (Yale Univ. Press 2002).
54. For information on state capacity and autonomy in general in Canada, see Governing Canada: Institutions and Public Policy (Michael Atkinson ed., Harcourt Brace & Co. 1993).
55. Leonard Marsh, Report on Social Security for Canada (E. Cloutier 1943)
56. Sandra Burt, Organized Women's Groups and the State, in Policy Communities and Public Policy in Canada 191 (W.D. Coleman & G. Skogstad eds., Copp Clark Pitman 1990).
57. Porter, supra note 14, at 62.
58. Id. at 64-68. Porter notes that pregnant women were generally considered unable to work six weeks before their due date and six weeks after, which made them ineligible for benefits, although some women were able to demonstrate their ability to work if they obtained a doctor's certificate, their family circumstances required them to work, they showed themselves physically capable of working, and their employer was not too embarrassed to have them seen in the workplace.
59. Id. at 73-75.
60. Burt, supra note 42, at 202.
61. Porter, supra note 14, at 79-80.
62. Id.
63. Royal Commission on the Status of Women in Canada, Report of the Royal Commission on the Status of Women in Canada (Information Canada 1970).
64. See Porter, supra note 14, at 83 and, generally, ch. 3.
65. Canada Labour Code, R.S.C. 1985, ch. L-2, §st 204-209.
66. Unemployment Insurance Act, 1971, supra note 2.
67. Burt, supra note 42, at 203.
68. Id.
69. Bliss v. Canada (Attorney General), [1979] 1. S.C.R. 183.
70. Unemployment Insurance Act, 1971, supra note 2, at §17(2)(a).
71. Bliss v. Canada, supra note 55, at 189.
72. Id. at 190.
73. Id. at 190-191.
74. Bill C-156, An Act to Amend the Unemployment Insurance Act, 1971 (no. 3), S.C. 1980-81-82-83, ch. 150.
75. The Canadian Charter of Rights and Freedoms, enacted as Schedule B to the Canada Act 1982 (U.K.) 1982, ch. 11, which came into force on Apr. 17, 1982, constitutionalizes a number of rights and freedoms.
76. From a letter to Doris Anderson, President of the National Action Committee on the Status of Women (NAC), quoted in, Annis May Timpson, Trudeau, Women and the Mystic North, 12 London J. Can. Stud. 41, 57 n. 15 (2002/2003).
77. Canada Assistance Plan, S.C. 1966, ch. 45, repealed by S.C. 1995, ch. 17, §32.
78. Canada Health and Social Transfer, Federal-Provincial Fiscal Arrangements Act, R.S.C. 1985, ch. F-8, pt. V.
79. See summary of the Québec government's actions in the Québec Court of Appeal ruling, Reference re: The Constitutionality of Sections 22 and 23 of the Employment Insurance Act), 2004 Can LII 28398 (QC C.A.).
80. Id.
81. Id. at para. 101.
82. Rheal Seguin, Québec to Assume Control of Parental-Leave Program, The Globe and Mail, May 20, 2004, at A12.
83. Reference re: Employment Insurance Act (Can.), 2005 S.C.C. 56, §22 and 23.
84. Canada, House of Commons, Standing Committee on the Status of Women, supra note 22, at 17.
85. Employment policies relating to pregnancy and childbirth, 29 C.F.R. § 1604.10 (1975)
86. see also Erin Kelly & Frank Dobbin, Civil Rights Law at Work: Sex Discrimination and the Rise of Maternity Leave Policies, 105 Amer. J. Sociology 455, 456 (1999).
87. General Electric Co. v. Gilbert, 429 U.S. 125, 145-146 (1976).
88. Id. at 496-497.
89. Geduldig v. Aiello, 417 U.S. 484 (1974).
90. An Act to amend title VII of the Civil Rights Act of 1964 to prohibit sex discrimination on the basis of pregnancy, Pub. L. No. 95-555 (1978).
91. Roberta Spalter-Roth, Claudia Withers, and Sheila Gibbs, Improving Employment Opportunities for Women Workers: An Assessment of the Ten-Year Economic and Legal Impact of the Pregnancy Discrimination Act of 1978 (IWPR 1990).
92. Heidi Hartmann & Young-Lee Yoon, Using Temporary Disability Insurance to Provide Paid Family Leave: A Comparison with the Family and Medical Leave Act, Research in Brief 1 (IWPR 1996).
93. California Federal Savings and Loan v. Guerra, 479 U.S. 272 (1987).
94. California Fair Employment and Housing Act, §12945(b)(2).
95. Guerra, supra note 78, at 279.
96. Id. at 278
97. Lisa Vogel, Debating Difference: Feminism, Pregnancy, and the Workplace, 16 Feminist Stud. 9, 10 (1990).
98. Id. at 284.
99. Id. at 287.
100. Parental and Disability Leave Act, 1985 H.R. 2020, 99th Cong., 131 CONG. REC. 8318 (1985)
101. Zigler, Finn-Stevenson & Hall, supra note 40, at 48.
102. For works detailing passage of the FMLA, see, for example, Ronald D. Elving, Conflict and Compromise (Simon & Schuster 1995)
103. Anya Bernstein, The Moderation Dilemma (Univ. Pittsburgh Press 2001)
104. and Wisensale, supra note 28.
105. Rhode Island in 1942, California in 1946, New Jersey in 1948, and New York in 1949, followed by Puerto Rico in 1968, and Hawaii in 1969.
106. Steven K. Wisensale, Two Steps Forward, One Step Back: The Family and Medical Leave Act as Retrenchment Policy, 20 Rev. Pol'y Res. 142 (2003)
107. Wisensale, supra note 28, at 119
108. National Partnership for Women and Families, State Legislative Round-up (NPWF 2004), available at http://www.nationalpartnership.org.
109. Hartmann & Yoon, supra note 77, at 2.
110. Employment Insurance Act, 1996, ch. 23, §12(3)(a)
111. Eileen Trzcinski & William T. Alpert, Pregnancy and Parental Leave Benefits in the United States and Canada: Judicial Decisions and Legislation, 29 J. Hum. Resources 535, 536 (1994).
112. Wisensale, supra note 28, at 186.
113. Id. at 188.
114. Id. at 190.
115. Birth and Adoption Unemployment Compensation, 20 C.F.R. pt. 604 (2000)
116. see also Zigler, Stevenson & Hall, supra note 41, at ch. 3.
117. Wisensale, supra note 87, at 142, lists them as California, Connecticut, Georgia, Illinois, Indiana, Maine, Massachusetts, Maryland, Minnesota, New Hampshire, New Jersey, Vermont, and Washington.
118. Id. at 142.
119. Wisensale, supra note 28, at 188.
120. Institute for Women's Policy Research (IWPR), Paid Family and Medical Leave: Essential Support for Working Women and Men, IWPR Fact Sheet (November 2000).
121. Denise Urias Levy and Sonya Michel, More Can Be Less: Child Care and Welfare Reform in the United States, in Child Care Policy at the Crossroads 239 (Sonya Michel & Rianne Mahon eds., Routledge 2002).
122. Carnegie Corporation, Starting Points: Meeting the Needs of our Youngest Children (1994)
123. for data on current child care arrangements, see Julia Overturf Johnson, Who's Minding the Kids? Child Care Arrangements: Winter 2002, Current Population Reports, 70-101 (U.S. Census Bureau 2005)
124. Levy & Michel, supra note 98, at 250.
125. California Family Temporary Disability Insurance Program, Cal. Unemp. Ins. Code §3301 (2002).
126. Labor Project for Working Families, Putting Families First: How California Won the Fight for Paid Family Leave 4 (2003), available at laborproject.berkeley.edu.
127. Id.
128. Steven K. Wisensale, California's Paid Leave Law: A Model for Other States?, paper presented at the Annual Meeting of the American Political Science Association, Philadelphia, Aug. 28, 2003, at 14, available at www.apsanet.org.
129. Nevada Department of Human Resources v. Hibbs, 538 U.S. 721 (2003).
130. See, e.g., Board of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356 (2001).
131. Nevada v. Hibbs, supra note 105, at 735-740.
132. See, e.g., Elving, supra note 85
133. Wisensale, supra note 28.
134. Berkeley Media Studies Group, Making the Case for Paid Family Leave: How California's Landmark Law was Framed in the News, Issue #14 (2003).
135. Kelly & Dobbin, supra note 71, at 456.
136. Gender and Public Poijcy: Cases and Comments 239-240 (Kenneth Winston & Mary Jo Bane eds., Westview Press 1993).
137. Personal interview, Aug. 24, 2004, Washington, D.C. (transcript on file with author).
138. Wisensale, supra note 87, at 136.
139. IWPR, supra note, 97, at 1, citing a survey by the CIVITAS Initiative, Zero to Three, and Brio Corporation, report that approximately 80 percent of those surveyed in 2000 reported that they supported paid parental leave, and even more, 85 percent favored paid leave to care for a new child or seriously ill family member.
140. The National Partnership for Women and Families, Expecting Better: A State-by-State Analysis of Parental Leave Programs (2005), available at www. nationalpartnership.org, reports that 84 percent of adults support the expansion of either disability or unemployment insurance programs in order to provide some kind of paid family and medical leave.
141. Sonya Michel's book title on the history of child care in the United States captures the divide well: Children's Interests/Mothers' Rights (Yale Univ. Press 1999).
142. Many of the social welfare programs introduced in the early decades of the twentieth century in the U.S. were designed to support women in the home so that they need not work but excluded black women, some immigrants, and women who did not meet standards of sexual morality. See Molly Ladd-taylor, Mother-Work (Univ. Ill. Press 1994)
143. Theda Skocpol, Protecting Soldiers and Mothers (Harvard Univ. Press 1992)
144. Jill Quadagno, The Color of Welfare (Oxford Univ. Press 1994)
145. Felicia A. Kornbluh, The New Literature on Gender and the Welfare State: The U.S. Case, 22 Feminist Studies 171 (1996). The Aid to Dependent Children program (later Aid to Families with Dependent Children) was supposed to be universally available but Mink argues that many children of unmarried women and women of color still were excluded under "suitable home," "man in the house," and "substitute father" rules, and bans against sexual cohabitation.
146. Gwendolyn Mink, Welfare's End (Cornell Univ. Press 1998).
147. Barbara Bergmann, The Only Ticket to Equality: Total Androgyny, Male Style, 9 J. Contemp. Legal Issues 9 (1998).
148. Maryann Barakso, Governing NOW (Cornell Univ. Press 2004)
149. Dorothy Sue Cobble, The Other Women's Movement 216-219 (Princeton Univ. Press 2004).
150. Marcia Cohen, The Sisterhood 141, 208 (Fawcett Columbine 1988).
151. Barakso, supra note 118 (although some organizations, such as the National Partnership for Working Families, are very supportive of paid leaves, and the Women's Committee of 100, formed in solidarity with poor women affected by the 1996 welfare reform measures, are sympathetic to the idea of mothers' allowances for poor women).
152. Id. at 122; currently NOW's website lists family issues as one of its key issues. Yet while it endorses state initiatives to use UI laws to allow women to collect benefits while caring for a newborn or newly adopted child (the so-called "Baby UI"), the website states that "Baby UI is not a substitute for comprehensive paid family leave." NOW, NOW and Family Issues, available at www.now.org.
153. Personal interview, June 28, 2004, Washington, D.C (transcript on file with author)
154. see also Bergmann, supra note 117.
155. Supra note 78.
156. Vogel, supra note 81.
157. Miller-Wohl Company, Inc., v. Commissioner of Labor and Industry, 692 P. 2d 1243, 1252 (Mont. 1984).
158. Id. at 1248.
159. Id.
160. See also Wendy Williams, Equality's Riddle: Pregnancy and the Equal Treatment/Special Treatment Debate, 13 NYU Rev. L. & Soc. Change 325 (1984-1985).
161. Wisensale, supra note 28, at ch. 6.
162. Canadian legal scholar Mary Jane Mossman, for example, writes, "To compare pregnancy, which is a positive and life-giving experience for women, with a temporary disability, which interrupts work activity and is often considered to be a negative, sometimes even life-threatening, circumstance seems problematic." Feminism and the Law: Challenges and Choices, 10 CAN. J. Women & L. 1-9 (1998).
163. Brooks v. Canada Safeway Ltd., [1989] 1 S.C.R. 1219.
164. Id. at 1250.
165. Id. at 1243-1244.
166. Id. at 1220.
167. Id. at 1237.
168. Women's Legal Education and Action Fund (LEAF), About LEAF: Brief Case Descriptions, available at www.leaf.ca/about-descriptions.html.
169. Alberta Hospital Association v. Parcels, [1992] 1 Alta. L.R. (3d) 332.
170. Id. at 344.
171. Id. at 337.
172. Id. at 340.
173. Muller v. Oregon, 208 U.S. 412 (1908), at 422-423.
174. Goesaert v. Cleary, 335 U.S. 464 (1948), at 466-467.
175. Hoyt v. Florida, 368 U.S. 57 (1961), at 59-65.
176. For an overview of the equal treatment perspective, see Williams, supra note 128.
177. See, for example, NOW's statement regarding pregnancy and equality: "[W]e make clear that women do not seek preferential, special or protected treatment because of pregnancy." NOW, Who Needs an Equal Rights Amendment? You Do!, available at www.now.org/issues/economic/cea/ who.html.
178. See, for example, past NOW President Patricia Ireland's, Women's Less Than Full Equality Under the Constitution, Perspectives (1997), and the National Council of Women's Organizations' (NCWO) endorsement of the United Nations Convention on the Elimination of All Forms of Discrimination against Women on the basis that it would "urge that the same 'strict scrutiny' apply to U.S. claims of unintentional sex discrimination as now applies to claims of race discrimination," available at www.womensorganizations.org/pages.cfm?ID=57.