Hall v. Nalco Company

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In Brief

Overruling the District Court, the Seventh Circuit decided that the employer’s decision to terminate an employee who took time off to undergo in vitro fertilization was actionable under Title VII.

 

What Happened in Court

Cheryl Hall was a secretary working for Nalco Company. She alleged that her employer terminated her because she took time off to undergo in vitro fertilization. After the District Court concluded that such a claim was not actionable under Title VII as amended by the Pregnancy Discrimination Act, the Seventh Circuit reversed. The Court of Appeals found that such conduct – discrimination based on IVF treatment – could be actionable under Title VII and permitted Hall to bring her claim against Nalco.