Serednyj v. Beverly Healthcare, LLC, 656 F.3d 540

Serednyj was an Activity Director at Beverly's Golden Living in Valparaiso, IN, from Aug 2006 to Mar 2007.
After learning of her pregnancy, she faced pregnancy complications and was placed on bed rest and then light duty restrictions by her doctors.
Beverly denied accommodation under its modified work policy, informing her she was not eligible for light duty because the policy covers only non-work-related injuries.
Serednyj was terminated in March 2007 after being unable to perform duties with restrictions, while she later learned she could return in June 2007 with lifted restrictions.
She alleged gender discrimination under Title VII as amended by the PDA, pregnancy discrimination, ADA disability discrimination, and retaliation.
The district court granted summary judgment for Beverly; the Seventh Circuit affirmed, upholding the policy and ruling on each statutory theory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
PDA/direct evidence viability	Serednyj asserts pregnancy discrimination under PDA; policy is discriminatory.	Policy is neutral and pregnancy-blind, denying light duty only for non-work injuries.	Policy valid; not direct evidence of discrimination.
Indirect proof under McDonnell Douglas	Circumstantial mosaic shows discriminatory intent against pregnant employee.	No similarly situated nonpregnant employee treated differently; lack of prima facie case.	No genuine issue; plaintiff failed to show a prima facie case.
ADA disability definition (§12102(2)(A))	Pregnancy complications may constitute a disability affecting major life activities.	Pregnancy-related conditions are not disabilities unless unusual circumstances show substantial limitation.	Complications did not substantially limit major life activities; not a disability.
ADA disability definition (§12102(2)(B))	Record of disability exists due to impairment.	No substantial impairment shown.	No record of disability; fails as a matter of law.
ADA disability definition (§12102(2)(C))	Beverly regarded her as disabled due to pregnancy complications.	Employer did not misperceive conditions or rely on stereotypes.	No 'regarded as' disability maintained; claim fails.
Retaliation	Filing accommodation request triggered retaliation and firing.	Termination occurred before or independent of protected activity; no adverse action tied to protected activity.	Summary judgment affirmed; no retaliation established.

Griffin v. Sisters of St. Francis, Inc., 489 F.3d 838 (7th Cir.2007) (pregnancy discrimination treated as sex discrimination under PDA)
Troupe v. May Department Stores Co., 20 F.3d 734 (7th Cir.1994) (convincing mosaic circumstantial evidence standard)
Piraino v. Int'l Orientation Resources, Inc., 84 F.3d 270 (7th Cir.1996) (PDA requires equal treatment with nonpregnant employees)
Dormeyer v. Comerica Bank-Illinois, 223 F.3d 579 (7th Cir.2000) (PDA limits accommodations to those comparable across genders)
Basith v. Cook County, 241 F.3d 919 (7th Cir.2001) (consideration of essential functions and job descriptions in disability analysis)
Payne v. State Student Assistance Comm., 2009 WL 1468610 (S.D. Ind. 2009) (pregnancy-related hypertension not a substantial limitation)
Gabriel v. City of Chicago, 9 F.Supp.2d 974 (N.D. Ill. 1998) (pregnancy-related standing impairment issue discussed)
Darian v. Univ. of Massachusetts Boston, 980 F. Supp. 77 (D. Mass. 1997) (pregnancy complications may be treated as impairments under unusual circumstances)