A recent ruling by the United States District Court for the District of Columbia denied an employer's motion for summary judgment, holding that a former employee's lawsuit under the FMLA should be allowed to proceed to trial.  In Breeden v. Novartis Pharmaceuticals, the plaintiff was a former pharmaceuticals sales rep whose sales territory was cut in half when she announced that she was pregnant.  Upon her return from FLMA maternity leave, her position was eliminated entirely at the recommendation of an outside consulting firm.  Although the employer asserted that plaintiff's maternity leave was not a consideration in the decision to eliminate her position, her pregnancy was mentioned in a PowerPoint presentation that the consulting firm prepared regarding the realignment.  Based on the evidence presented during the parties' summary judgment briefings, the appellate court concluded that a reasonable jury could find that the employer's actions constituted unlawful retaliation.