In California Federal Savings and Loan Association. v. Guerra, (1987) 479 U.S. 272, 285, 107 S.Ct. 683, 93 L.Ed.2d 613 (1987) the U.S. Supreme Court noted that "Congress intended the PDA to be 'a floor beneath which pregnancy disability benefits may not drop - not a ceiling above which they may not rise.'" In Guerra, the high Court analyzed a California statute that required employers to provide female employees unpaid pregnancy disability leave of up to four months. The state agency authorized to interpret the statute, the Fair Employment and Housing Commission, construed the statute to require California employers to reinstate an employee returning from such pregnancy leave to the job she previously held, unless it is no longer available due to business necessity. In the latter case, the employer must make a reasonable, good faith effort to place the employee in a substantially similar job. A California employer and trade associations sought a declaration that the statute was inconsistent with and was pre-empted by Title VII. The District Court agreed, finding that "California state law and policies of interpretation and enforcement ... which require preferential treatment of female employees disabled by pregnancy, childbirth, or related medical conditions are pre-empted by Title VII and are null, void, invalid and inoperative under the Supremacy Clause of the United States Constitution." California Federal Sav. And Loan Ass'n v. Guerra, 1984 U.S. Dist, 33 Empl. Prac. Dec. P 34, 227 (C.D.Cal. Mar 21, 1984). The United States Court of Appeals for the Ninth Circuit reversed. California Federal Sav. And Loan Ass'n v. Guerra, 758 F.2d 390 (9th Cir.1985). It held that "the district court's conclusion that the law discriminates against men on the basis of pregnancy defies common sense, misinterprets case law, and flouts Title VII and the PDA." Id. at 393. The Court of Appeals found that the PDA does not "demand that state law be blind to pregnancy's existence." Id. at 395. Because it found that the California statute furthers the goal of equal employment opportunity for women, it concluded: "Title VII does not preempt a state law that guarantees pregnant women a certain number of pregnancy disability leave days, because this is neither inconsistent with nor unlawful under Title VII." Id. The U.S Supreme Court affirmed. Justice Marshall delivered the Court's opinion and noted that the California law promotes equal employment opportunity by ensuring that women will not lose their jobs on account of pregnancy disability. Guerra, at 288. The law "does not compel California employers to treat pregnant workers better than other disabled employees; it merely establishes benefits that employers must, at a minimum, provide to pregnant workers. Employers are free to give comparable benefits to other disabled employees, thereby treating "women affected by pregnancy" no better than "other persons not so affected but similar in their ability or inability to work." Id. at 289. Importantly, the U.S. Supreme Court also stated: "The statute is narrowly drawn to cover only the period of actual physical disability on account of pregnancy, childbirth, or related medical conditions. Accordingly, unlike the protective labor legislation prevalent earlier in this century, the statute does not reflect archaic or stereotypical notions about pregnancy and the abilities of pregnant workers. A statute based upon such stereotypical assumptions would, of course, be inconsistent with Title VII's goal of equal employment opportunity." Id. at 290.