Boyne v. Town & Country Pediatrics and Family Medicine, 3:15-cv-01455

Plaintiff Michelle Boyne worked as a full‑time medical assistant/receptionist for Town and Country Pediatrics from 2010 until June 2014; she was initially accommodated with light duty after pregnancy complications in 2011 (diagnosed with HELLP syndrome).
In late 2013/early 2014 Boyne became pregnant again, experienced complications from HELLP, was placed on light duty/no bending or lifting, and provided medical notes to her employer.
Boyne requested to work reduced receptionist hours consistent with restrictions; defendant denied those requests, told her she could not return during pregnancy, later informed her the position had been filled, and ultimately terminated her employment on June 30, 2014.
Boyne filed CHRO/EEOC charges on July 18, 2014 and later sued in federal court alleging pregnancy discrimination under Title VII (Count One) and disability discrimination/failure to accommodate under the ADA (Count Two).
Defendant moved to dismiss the Second Amended Complaint; the court evaluated whether Boyne plausibly alleged pregnancy discrimination and whether she exhausted administrative remedies for her ADA claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Boyne plausibly alleged pregnancy discrimination under Title VII (PDA)	Boyne alleges she was denied light‑duty accommodation, repeatedly requested to perform receptionist duties within restrictions, was kept in contact with employer, and then terminated shortly after her pregnancy/leave — raising inference of discrimination	Employer contends plaintiff failed to plead prima facie case, specifically lacking identification of similarly situated non‑pregnant employees treated better	Court denied motion as to Count One: allegations (temporal proximity, repeated accommodation requests, replacement hires, and statements about multiple pregnancies in office) suffice to raise plausible inference of discrimination
Whether Boyne exhausted administrative remedies for her ADA disability / failure‑to‑accommodate claim	Boyne argues CHRO/EEOC filings referenced HELLP syndrome, detailed medical restrictions and requests for accommodation, and thus gave adequate notice to investigate disability claims related to pregnancy complications	Employer contends CHRO complaint did not mention “disability” or a non‑pregnancy medical condition and so did not properly exhaust ADA claim	Court denied motion as to Count Two: CHRO complaint referenced HELLP syndrome, ongoing medical restrictions, and accommodation requests; ADA claim is reasonably related to CHRO allegations and was exhausted

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (motion to dismiss plausibility standard)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards and plausibility)
Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (discrimination pleading in Title VII cases)
E.E.O.C. v. Port Auth. of N.Y. & N.J., 768 F.3d 247 (ALJ/pleading principles applied to discrimination claims)
Kerzer v. Kingly Mfg. Co., 156 F.3d 396 (prima facie elements for pregnancy discrimination)
Williams v. N.Y. City Hous. Auth., 458 F.3d 67 (what is "reasonably related" for EEOC/CHRO exhaustion)
McInerney v. Rensselaer Polytechnic Inst., 505 F.3d 135 (EEOC charge timing/exhaustion principles under ADA)
Bragdon v. Abbott, 524 U.S. 624 (reproduction as a major life activity under ADA)
El Sayed v. Hilton Hotels Corp., 627 F.3d 931 (temporal proximity can support inference of discrimination/retaliation)
Dollman v. Mast Indus., Inc., 731 F. Supp. 2d 328 (lack of specific non‑pregnant replacement allegation nonetheless may permit inference of discrimination)