The ink had barely dried on the Supreme Court's 1976 opinion in General Electric Co. v. Gilbert when a coalition of women's activists, feminist lawyers, civil rights groups, and labor organizations began drafting legislation to nullify the Court's ruling. Shortly thereafter, Congress enacted the 1978 Pregnancy Discrimination Act (PDA). The PDA overturned Gilbert by amending Title VII of the 1964 Civil Rights Act to explicitly prohibit employment discrimination on the basis of pregnancy or pregnancy-related conditions. The PDA made clear once and for all that pregnancy discrimination was, by definition, sex discrimination barred by Title VII.
"Discrimination by Definition: The Historical and Legal Paths to the Pregnancy Discrimination Act of 1978,"
Yale Journal of Law & Feminism: Vol. 21
, Article 2.
Available at: http://digitalcommons.law.yale.edu/yjlf/vol21/iss1/2