Pregnancy Discrimination Act

In Van Soeren v. Disney Streaming Service, 2020 WL 6131255 (S.D.N.Y. Oct. 16, 2020), the court dismissed plaintiff’s discrimination complaint asserted under, e.g., Title VII of the Civil Rights Act of 1964. In sum, plaintiff – a male product designer and former at-will employee of defendant – asserted that he was subject to pregnancy discrimination…

Read More Title VII Discrimination Claim, Based on Wife’s Pregnancy, Dismissed; “New Parent” Status Not Protected Class
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In Barton et al v. Warren County et al, 2020 WL 4569465 (N.D.N.Y. August 7, 2020), the court, inter alia, dismissed plaintiffs’ gender/pregnancy-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964.[1]Here, for the sake of narrowing the discussion, I’ll discuss the court’s evaluation of the claims asserted by…

Read More Pregnancy-Related Title VII Hostile Work Environment Claim Dismissed; Three Alleged Remarks in One-Month Period Insufficiently “Severe” or “Pervasive”
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In Vivian Xiang v. Eagle Enterprises, LLC, 19-cv-1752, 2020 WL 248941 (S.D.N.Y. January 16, 2020), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s pregnancy discrimination claim, asserted under Title VII of the Civil Rights Act of 1964. The law, as summarized by the court: A plaintiff must plead sufficient facts to show that…

Read More Pregnancy Discrimination Claim Sufficiently Alleged
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In Lenzi v. Systemax, Inc., No. 18-979, 2019 WL 6646630 (2d Cir. Dec. 6, 2019), the court, inter alia, reinstated plaintiff’s claims – dismissed below by summary judgment – of pay discrimination, pregnancy discrimination, and retaliation claims under Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleged that defendants paid her…

Read More 2d Circuit Revives Title VII Pay Discrimination Claim
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In Colas v. City of University of New York, 17-cv-4825, 2019 WL 2028701 (E.D.N.Y. May 7, 2019), the court, inter alia, dismissed plaintiff’s pregnancy-based hostile work environment and constructive discharge claims. As to plaintiff’s hostile work environment claim, the court explained: Here, Defendants contend that Plaintiff’s allegations “amount to dissatisfaction with her supervisors, … personality…

Read More Pregnancy-Based Hostile Work Environment, Constructive Discharge Claims Dismissed Against CUNY
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This week, in Legg v. Ulster Cty., No. 14-3636, 2016 WL 1637993 (2d Cir. Apr. 26, 2016), the Second Circuit reinstated a pregnancy discrimination claim brought by an Ulster County Corrections Officer. Plaintiff argued that the defendant County “unlawfully discriminated against her on the basis of her pregnancy when it denied her request for an accommodation under…

Read More Second Circuit Reinstates Pregnancy Discrimination Claim in Light of Young v. UPS
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In Ramsaran v. Booz & Co. (N.A.) Inc., No. 1:14-CV-708-GHW, 2015 WL 5008744 (S.D.N.Y. Aug. 24, 2015), the Southern District of New York granted defendant’s motion for summary judgment on plaintiff’s pregnancy discrimination claim. In sum: After a series of documented negative reviews regarding her job performance, Ms. Ramsaran was fired. At the time that…

Read More Pregnancy Discrimination Case Dismissed
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In Young v. United Parcel Service, Inc., 135 S.Ct. 1338 (March 25, 2015), the U.S. Supreme Court interpreted and applied a portion of the Pregnancy Discrimination Act relating to accommodations that covered employers must make to pregnant workers. The Pregnancy Discrimination Act, codified at 42 U.S.C. § 2000e(k), amends Title VII of the Civil Rights Act of…

Read More U.S. Supreme Court Interprets Title VII’s Pregnancy Discrimination Act; Vacates Judgment Against Pregnant Employee
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