Elaine W. v. Joint Diseases North General Hospital (N.Y. 1993)

In Elaine W. v. Joint Diseases North General Hospital, 81 N.Y.2d 211 (1993), pregnant women who were denied admission to an inpatient detoxification program challenged the hospital’s categorical exclusion as sex discrimination under New York State's  Human Rights Law. The hospital defended its policy on safety grounds, asserting that it lacked obstetrical services and could not treat any pregnant patient. The Court of Appeals held that a blanket ban on all pregnant women could violate the statute because pregnancy is a condition unique to one sex and therefore cannot be the basis for automatic exclusion. The Court explained that the Human Rights Law requires an individualized medical assessment unless the provider can show that such an evaluation is impossible or that admission would pose unavoidable dangers. By rejecting broad pregnancy-based exclusions without demonstrated medical necessity, the decision strengthened protections against discriminatory treatment of pregnant patients in healthcare settings.