This month, we discuss Legg v. Ulster County,1 in which the U.S. Court of Appeals for the Second Circuit, in an issue of first impression, found that the denial of a light-duty accommodation to the pregnant employee of a county correctional facility was sufficient to support an inference of discrimination under the Supreme Court’s recently announced “significant burden” standard for proof of pregnancy discrimination under Title VII, as amended by the Pregnancy Discrimination Act of 1978 (PDA).2
This case involved a county sheriff’s refusal to provide a light-duty accommodation to the county’s only pregnant corrections officer, despite a policy of providing such accommodation to workers injured on the job. The circuit examined for the first time whether such a denial would impose a “significant burden” on pregnant employees without sufficient justification, supporting an inference of discrimination under the Supreme Court’s 2015 ruling in Young v. United Parcel Service.3
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