Legg v. Ulster County
820 F.3d 67
2d Cir.2016Background
- Ann Marie Legg, a corrections officer at Ulster County Jail, sought a light‑duty accommodation during a high‑risk pregnancy; the County’s light‑duty policy limited eligibility to employees injured on the job.
- Legg’s doctor recommended limited inmate contact; initial informal accommodation was promised but later rescinded and she was required to resume full duty until she left after a health scare.
- Legg sued Ulster County and Sheriff VanBlarcum under Title VII as amended by the Pregnancy Discrimination Act (PDA), alleging pregnancy discrimination for denial of accommodation.
- At the close of Legg’s case the district court granted Rule 50 judgment as a matter of law, finding the light‑duty policy facially neutral and not discriminatory; other claims proceeded and a jury ruled for plaintiff Watson on hostile‑work‑environment.
- While the appeal was pending, the Supreme Court decided Young v. UPS, which created a framework for assessing pregnancy accommodation claims under the PDA where an employer’s facially neutral policy excludes pregnant workers.
- The County also appealed denial orders: the district court had granted a post‑trial extension to file Rule 50(b)/59 motions but later denied the motions as untimely for lack of jurisdiction under Rule 6(b)(2).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Legg presented sufficient evidence to survive a Rule 50 JMOL on her pregnancy discrimination claim under the PDA | Legg argued the County’s light‑duty‑for‑on‑duty‑injuries policy excluded pregnant employees who were similar in ability to work and thus created an inference of discrimination under Young | County argued the policy was facially neutral (distinguished by source of injury) and justified by compliance with New York workers’‑compensation statutory scheme | Vacated judgment as to Legg; under Young Legg made a prima facie showing and raised sufficient evidence of pretext and significant burden to send claim to a jury; remand for new trial |
| Whether the County’s asserted justification (compliance with state law/cost) is legally sufficient to defeat PDA disparate‑treatment claim | Legg argued compliance with state law/cost were pretextual given inconsistent justifications and categorical exclusion of pregnant employees | County argued GML § 207‑c and fiscal concerns justified limiting light duty to on‑duty injuries | Court held compliance with state law is a legitimate non‑discriminatory explanation that shifts burden back to Legg to prove pretext; but evidence (inconsistent testimony, categorical exclusion, cost motives) could allow a reasonable jury to find pretext |
| Whether denial of accommodation imposed a "significant burden" on pregnant employees under Young | Legg argued the categorical exclusion caused a significant burden (100% of pregnant employees denied) and placed them at risk performing inmate contact | County argued few pregnant employees were affected and Legg was able to perform duties or chose to stop working | Court held a jury could find a significant burden: Young focuses on denial rate among pregnant employees; here pregnant employees were categorically excluded and the only pregnant officer was denied |
| Whether the district court lacked jurisdiction to consider defendants’ post‑trial Rule 50(b) and Rule 59 motions because Rule 6(b)(2) prohibits extensions | County argued the district court’s extension was ineffective and the post‑trial motions were untimely, depriving the court of jurisdiction | Plaintiffs did not object to the extension below and the court nevertheless entertained the motions; defendants argued timeliness was jurisdictional | Court held Rule 6(b)(2) is not jurisdictional; the district court erred to deny motions for lack of jurisdiction and must decide whether waiver or equitable reasons permit consideration; vacated and remanded |
Key Cases Cited
- Young v. United Parcel Service, Inc., 135 S. Ct. 1338 (Sup. Ct. 2015) (PDA framework for pregnancy accommodation claims where a neutral policy excludes pregnant workers)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Sup. Ct. 1973) (burden‑shifting framework for disparate treatment claims)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Sup. Ct. 2000) (standard of review for JMOL and drawing inferences for non‑movant)
- Kontrick v. Ryan, 540 U.S. 443 (Sup. Ct. 2004) (distinguishing jurisdictional rules from claim‑processing rules)
- Eberhart v. United States, 546 U.S. 12 (Sup. Ct. 2005) (procedural time rules in criminal context non‑jurisdictional analog)