Summary 

On October 28, 2026, NWLC filed an amicus brief to the Eleventh Circuit Court of Appeals in Patel v. Baycare Health System, Inc., on appeal from the U.S. District Court for the Middle District of Florida. 

In this case, plaintiff Pamela Patel, a hospital employee, alleges that her employer discriminated and retaliated against her when the hospital-employer refused to provide workplace accommodations related to her pregnancy and childbirth, in violation of the Pregnant Workers Fairness Act (PWFA). The district court granted summary judgment to the hospital, and she is now asking the Eleventh Circuit to reverse. 

Our brief explains that Congress passed the PWFA to fill long-standing gaps in federal law that failed to protect pregnant workers, forcing them onto unpaid leave or pushing them out of work entirely. The PWFA establishes—for the first time—an affirmative right to reasonable accommodations for known limitations related to pregnancy, childbirth, and related medical conditions, unless providing such accommodations would create an undue hardship for the employer. Drawing on the PWFA’s legislative history, our brief recounts that Congress acted in direct response to the failure of the Americans with Disabilities Act (ADA) and the Pregnancy Discrimination Act (PDA) to meet pregnant workers’ needs, which was compounded by courts’ narrow interpretations of those statutes in the pregnancy context. 

Because no federal court of appeals has yet determined what a worker must show to make out a prima facie case of discrimination under the PWFA, this case is an important opportunity to get the standard right. Our brief urges the court not to import burdensome requirements from other statutes into the PWFA. Congress wrote the PWFA to remove those barriers for pregnant workers, and courts should not put them back.