In Doe v. C.A.R.S. Protection Plus, Inc., 527 F.3d 358 (3d Cir. 2008), the Third Circuit reversed summary judgment for the employer on the plaintiff’s claim of discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., as amended by the Pregnancy Discrimination Act, 42 U.S.C. § 2000e(k) (the “PDA”). The plaintiff, a graphic artist, claimed that her employer, a company that insures used cars, discharged her because she had an abortion. The Third Circuit had not previously addressed the issue of whether the PDA protects employees from discrimination for having an abortion. Based upon the PDA’s “plain language” and “legislative history,” and the “EEOC guidelines,” the Court concluded that it does. Applying a modified McDonnell Douglas burden-shifting analysis, the Court determined that genuine issues of material fact precluded summary judgment and remanded the case to the district court.