PWFA Claims Have Arrived: Anatomy of a Lawsuit

Why It Matters

The decision signals that employers must rigorously document accommodation efforts and cannot rely on vague job descriptions to avoid PWFA liability, reshaping compliance strategies across industries.

Key Takeaways

• Legacy failed to engage in interactive dialogue about accommodation.
• Judge denied Legacy’s motion to dismiss PWFA claim.
• Lifting restriction deemed potentially essential, but job description vague.
• Undue hardship defense requires concrete cost analysis, which Legacy omitted.

Pulse Analysis

The Pregnant Workers Fairness Act, enacted in 2023, gives pregnant employees the right to reasonable accommodations for work‑related limitations. While the law is relatively new, the King v. Legacy case demonstrates that courts are already scrutinizing employer compliance. Under the PWFA, employers must engage in an interactive process, assess whether a restriction impacts an essential job function, and explore feasible accommodations before taking adverse employment actions. Failure to do so can result in a claim surviving dismissal, as seen when the court rejected Legacy’s attempt to toss the lawsuit.

In this lawsuit, the crux hinged on three PWFA pillars: knowledge of the limitation, essential function analysis, and reasonable accommodation. Legacy knew King’s 25‑pound restriction but offered no dialogue, opting instead to terminate her. The job description’s vague reference to "lifting" under qualifications, rather than essential functions, left the essential‑function question unresolved, pushing the matter to a jury. Moreover, the employer’s undue‑hardship defense lacked concrete cost data, violating the statutory burden that requires detailed financial analysis. The court’s criticism of Legacy’s speculative arguments underscores the importance of factual, documented assessments when evaluating accommodation feasibility.

For HR leaders and business managers, the ruling serves as a cautionary tale. Companies should update job descriptions to clearly delineate essential duties, train managers on PWFA obligations, and establish a structured interactive‑process protocol that records all accommodation discussions and cost evaluations. Proactively engaging with employees and documenting the impact on operations can mitigate litigation risk and demonstrate good‑faith compliance, essential in an environment where PWFA claims are poised to increase.