In a notable development, the federal Seventh Circuit Court of Appeals has allowed a female former employee to proceed to trial on claims she was fired because she was undergoing in vitro fertilization treatment. In Hall v. Nalco Co., plaintiff Hall took medical leave to undergo in vitro fertilization. While undergoing a reorganization, the Company terminated Hall and told her that the termination “was in [her] best interest due to [her] health condition.” The Seventh Circuit stated: “Because adverse employment actions taken on account of childbearing capacity affect only women, Hall has stated a cognizable sex-discrimination claim under the language of the [Pregnancy Discrimination Act].”