General Electric Co., v. Gilbert

In General Electric Co., v. Gilbert (429 U.S. 125, 97 S. Ct. 401, 50 L. Ed. 2d 343 [1976]), the U.S. Supreme Court held that a company's disability plan that excluded disabilities arising from pregnancy was not discrimination because of sex prohibited by Title VII. In 1978, Congress overruled Gilbert with the Pregnancy Discrimination Act, amending the "Definitions" section of Title VII to provide, "The terms because of sex' or on the basis of sex' include, but are not limited to, because of or on the basis of pregnancy, childbirth, or related medical conditions; and women affected by pregnancy, childbirth, or related medical conditions shall be treated the same for all employment-related purposes." (See Newport News Shipbuilding & Dry Dock Co. v. EEOC, 462 U.S. 669, 670, 103 S. Ct. 2622, 77 L. Ed. 2d 89 [1983] [quoting 42 USC 2000e (k) (1976 ed., Supp. V)].)