The Virginia Court of Appeals issued a significant ruling on November 4, 2026, clarifying the causation standard in pregnancy discrimination cases under the Virginia Human Rights Act (VHRA). The case, Chanda Waldenmaier v. DBDriven.net, LLC, revolves around the termination of Chanda Waldenmaier, who claimed she was fired for using a reasonable accommodation related to her pregnancy. This ruling is crucial for employees seeking protections against discrimination in the workplace.

The court determined that the “motivating factor” standard applies to discrimination claims based on pregnancy accommodations, reversing a lower court’s decision that had applied a stricter “but-for” causation standard. This decision could impact how similar cases are handled in Virginia, providing clearer protections for pregnant employees.

Background

Chanda Waldenmaier began working for DBDriven.net LLC (DBD) in March 2021 as a business systems analyst. Shortly after learning of her pregnancy in November 2021, she requested a reasonable accommodation to work from home due to complications related to her pregnancy. DBD granted her request, allowing her to work remotely until her due date. However, in February 2022, DBD received a stop-work order on a major contract, which led to significant layoffs, including Waldenmaier's termination.

Waldenmaier filed a claim under Code § 2.2-3909 of the VHRA, alleging that her termination was due to her use of the pregnancy accommodation. DBD argued that her termination was based on the loss of the contract and her junior status within the company. The Circuit Court of Stafford County granted summary judgment in favor of DBD, concluding that Waldenmaier could not prove her pregnancy accommodation was the but-for cause of her termination.

The Ruling

The Court of Appeals of Virginia ruled that the “motivating factor” standard applies to claims under Code § 2.2-3909(B)(2). The judges noted, “We agree that the ‘motivating factor’ standard applies and conclude that the circuit court erred by granting summary judgment based on its application of a ‘but-for’ causation standard.” This decision means that if Waldenmaier can demonstrate that her pregnancy accommodation was a motivating factor in her termination, she may have a valid claim against DBD.

The court also addressed the admissibility of evidence in the case, agreeing with the lower court's decision to exclude a secretly recorded phone call between Waldenmaier and her supervisor, Will Goldschmidt. The court stated, “On remand, only admissible evidence can be considered in resolving the summary judgment motion.”

Impact

This ruling is significant for employees in Virginia, as it sets a precedent that could affect future pregnancy discrimination cases. By clarifying that the “motivating factor” standard applies, the court has made it easier for employees to prove discrimination claims related to pregnancy accommodations. This change aligns Virginia's law more closely with federal anti-discrimination laws, which often use a similar standard.

The decision also highlights the importance of reasonable accommodations for pregnant employees, reinforcing the idea that discrimination based on the use of such accommodations is unlawful. This could encourage more employees to come forward with claims of discrimination, knowing they have a clearer legal framework to support their cases.

What's Next

The case has been remanded to the lower court for further proceedings under the correct causation standard. It remains to be seen how the lower court will handle the case on remand, and whether DBD will appeal the ruling. This decision may also influence other pending cases involving pregnancy discrimination in Virginia.