employer must treat her the same as any other temporarily disabled employee; for example, by providing light duty, modified tasks, alternative assignments, disability leave, or leave without pay. An employer may have to provide a reasonable accommodation for a disability related to pregnancy, absent undue hardship (significant difficulty or expense)." Critical cases The Geduldig v. Aiello (1974) case involved a pregnant woman who was denied medical benefits under her disability insurance, citing the 14th Amendment, and claiming sex discrimination. The U.S. Supreme Court concluded that there was no evidence of sex discrimination, and that there was no violation of the Equal Protection Clause, as men and women were receiving equal protection under the insurance program, and that because men cannot become pregnant, offering protections for pregnancy would constitute unequal treatment. The court in this case also did not use a heightened level of scrutiny, meaning that the court did not treat this case as one of high importance. This treatment was criticized by Justice Brennan in a dissent in which he argued that physical gender differences should not lead to unequal compensation, and that gender cases should be decided using the strict scrutiny standard. General Electric v. Gilbert (1976) in many ways was influenced by the decision of Geduldig v. Aiello, as the Supreme Court again found no evidence of discrimination. Specifically, in General Electric v. Gilbert the Supreme Court ruled that it was legal for employers to exclude pregnancy-related conditions from employee sickness and accident benefits plans. Again, Justice Brennan dissented, noting for a second time that women were receiving unequal compensation. Due to this dissent and the dissent from Geduldig v. Aiello, U.S. Congress saw a gap in protections and created the Pregnancy Discrimination Act two years later in response. Other important cases Rentzer v. Unemployment Ins. Appeals Bd. (1973) Gail Rentzer suffered from an ectopic pregnancy and was therefore unable to work. She was denied compensation by the California Unemployment Insurance Appeals Board because they did not recognize pregnancy or related medical complications as a disability. But after a lawsuit was filed, the California Court of Appeals found that because Gail had not had a normal pregnancy and her emergency surgery was performed to stop bleeding and save her life, her pregnancy was deemed worthy of disability benefits. This case allowed women with medical complications during pregnancy to be granted benefits and more protections, such as disability